- 15 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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