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accrued over a substantial period of time'". Malat v. Riddell,
383 U.S. 569, 572 (1966) (quoting Corn Prods. Refining Co. v.
Commissioner, 350 U.S. 46, 52 (1955), and Commissioner v.
Gillette Motor Transp., Inc., 364 U.S. 130, 134 (1960)).
As used in section 1221(1), the word "primarily" means "of
first importance" or "principally." Malat v. Riddell, supra at
572. The question whether property is property described in
section 1221(1) is a factual inquiry. Pasqualini v. Commis-
sioner, 103 T.C. 1, 6 (1994). In resolving that question, the
courts have examined various factors, including the following:
(1) The purpose for which the property was acquired; (2) the
purpose for which it was held; (3) the frequency, continuity, and
substantiality of sales; (4) the duration of ownership; (5) the
use of the proceeds from the sale of the property; (6) the
business of the taxpayer; and (7) the time and effort that the
taxpayer devoted to sales activities relating to the asset in
question by developing or improving that asset, soliciting
customers, or advertising. See Graves v. Commissioner, 867 F.2d
199, 202 (4th Cir. 1989), affg. an Oral Opinion of this Court;
United States v. Winthrop, 417 F.2d 905, 910 (5th Cir. 1969);
Huey v. United States, 205 Ct. Cl. 551, 504 F.2d 1388, 1392
(1974); Maddux Constr. Co. v. Commissioner, 54 T.C. 1278, 1284
(1970); Hoover v. Commissioner, 32 T.C. 618, 627 (1959). No
single factor, or combination thereof, is necessarily control-
ling. Graves v. Commissioner, supra at 202. The foregoing
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