- 22 -                                         
          intention that they should be otherwise construed.12  See supra             
          note 8.  Inventory is, simply stated, property that is held for             
          sale.  Grant Oil Tool Co. v. United States, 108 Ct. Cl. 620, 381            
          F.2d 389, 397 (1967).                                                       
               We have found that the emulsified asphalt is not merchandise           
          held for sale by petitioner in the operation of petitioner's                
          service business, and that petitioner does not keep any raw                 
          materials or finished goods on hand.  Previously, the Court of              
          Appeals for the Second Circuit considered the fact that the                 
          taxpayer had no stock or merchandise on hand and no warehouse or            
          storeroom for merchandise, and that goods were delivered directly           
          from the manufacturer to the customer, to be conclusive in                  
          finding that the taxpayer did not maintain inventories.  See                
          Simon v. Commissioner, 176 F.2d 230, 232 (2d Cir. 1949) (buyer              
               12   "Inventory" is defined in The Random House College                
          Dictionary (1982) as:                                                       
               1. a detailed, often descriptive, list of articles, giving             
               the code number, quantity, and value of each; catalog. * * *           
               3. a complete listing of merchandise or stock on hand, raw             
               materials, etc., made each year by a business concern.  4.             
               the objects or items represented on such a list, as a                  
               merchant's stock of goods.  5. their aggregate value.                  
               Similarly, "inventory" is defined in Webster's Second New              
          International Dictionary (1957) as:                                         
               1. an account, catalog, or schedule, made by an executor or            
               administrator, of all the goods and chattels, and sometimes            
               of the real estate, of a deceased person; a list of the                
               property of a person or estate; hence an itemized list of              
               goods or valuables, with their estimated worth; specif., the           
               annual account of stock taken in any business; * * * 2.                
               Inventoriable goods, hence stock of such; * * * .                      
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