Allie Ray McCullen and Shurley G. McCullen - Page 15

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          no sales before or during the years in issue.  There is no                  
          persuasive evidence that petitioners tried to develop or sell               
          their property, solicit buyers, or advertise before or during the           
          years in issue.  Petitioners contend that the properties were               
          available for sale.  However, there is no evidence that they did            
          anything to make this fact known to prospective buyers.                     
          Petitioners contend that petitioner did not need to advertise               
          because his corporation did and he already had considerable name            
          recognition.  We disagree; his being well known was not a                   
          substitute for soliciting buyers, which is relevant to                      
          establishing his purpose in holding property.                               
               The record does not show when petitioners bought the Bass              
          Town and Giddonsville tracts.  Petitioner sold them after 1991.             
          A sporadic activity is not a trade or business.  Commissioner v.            
          Groetzinger, supra at 35; Polakis v. Commissioner, supra at 670-            
          671; Christian v. Commissioner, T.C. Memo. 1995-12.                         
               2.   Petitioners' Other Contentions                                    
               Petitioners contend that the fact that they farmed their               
          land does not show that they were not trying to sell it.  We                
          agree.  We did not consider the fact that they farmed some of the           
          land in deciding whether they had a trade or business of selling            
          real estate.                                                                
               Petitioners contend that the factors stated in Polakis v.              
          Commissioner, supra, and Christian v. Commissioner, supra, do not           
          apply here because the facts in those cases differ.  We disagree.           




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