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any specific party, let alone someone who was committed to pay
for it.
In Morley v. Commissioner, supra, the taxpayer was in the
trade or business of selling real estate for commission as a
broker. In September 1973, the taxpayer entered a contract
giving the taxpayer the right to purchase 180 acres of property
(the Elm Farm). The taxpayer did not have a particular
repurchaser in mind at the time he entered the contract but
intended promptly to attempt to resell the Elm Farm if he
purchased it. The taxpayer purchased the Elm Farm in December
1973. From September 1973 to February 1974, the taxpayer was
negotiating the sale of the Elm Farm to a third party (Mr.
Pflug). In February 1974, the real estate market collapsed, and
Mr. Pflug and the taxpayer terminated negotiations. Because of
the real estate market collapse, the taxpayer was unable to sell
the Elm Farm to other purchasers although he attempted to do so.
The Court stated that a taxpayer engaged in a single venture
can be found to be in a trade or business in "situations where,
at the time the property was acquired by the taxpayer, he
intended promptly to resell the property and the objective facts
show that he proceeded to attempt to implement that intent".
Morley v. Commissioner, supra at 1211. In finding that the
taxpayer was engaged in a trade or business regarding his
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