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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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