-18-
maintained. See Kesicki v. Commissioner, 34 T.C. 675, 678-679
(1960) (the taxpayer held property for investment even though he
did not develop it before he sold it).
Respondent contends that the fact that petitioner had held
the lots since 19873 suggests that she held them primarily for
investment. We disagree. A long holding period suggests
property was held for investment; alone, however, it does not
establish that a taxpayer held property for investment. See
Suburban Realty Co. v. United States, 615 F.2d at 184-185 (the
taxpayer's primary purpose for holding real estate up to 33 years
was for sale to customers); United States v. Winthrop, supra at
907, 909, 911 (the taxpayer held lots up to 25 years for sale to
customers); Walsh v. Commissioner, T.C. Memo. 1994-293 (income
from the sale of a parcel of 13 acres a taxpayer had held for 13
years was ordinary income), affd. without published opinion (8th
Cir., July 11, 1995); Tollis v. Commissioner, T.C. Memo. 1993-63
(the taxpayer's proceeds from the sale of 9 parcels of real
property over an 8-year period were ordinary income; his decision
to retire from the real estate business did not convert the
parcels into capital assets), affd. without published opinion 46
F.3d 1132 (6th Cir. 1995); Herndon v. Commissioner, T.C. Memo.
3 Respondent does not contend that we should consider the
fact that Hancock Enterprises held the lots from 1977 to 1986 in
deciding if petitioner held them for sale to customers.
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