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Hancock Enterprises had stopped building homes around 1982 or
1983. Second, the fact that Mark Hancock used the "Camelot
Homes" name does not show whether petitioner was still in the
trade or business of selling lots to customers.
Respondent contends that the fact that petitioner and her
husband held the lots for sale to customers through Hancock
Enterprises does not mean she held them for sale to customers in
1993 and 1994 because (a) Hancock Enterprises began to hold the
lots as an investment when it abandoned its plans to develop them
around 1983 and decided to hold them until market conditions
improved, and because (b) Hancock Enterprises' holding purpose is
irrelevant in deciding petitioner's holding purpose. We
disagree. First, Hancock Enterprises did not abandon its efforts
to sell its lots. Hancock Enterprises had about 115 lots when it
stopped building homes in 1982 or 1983, but it had only 48 lots
when it liquidated at the end of 1986. This shows that Hancock
Enterprises actively sold lots after it stopped building homes.
See Suburban Realty Co. v. United States, supra at 184 (the court
did not view the fact that the taxpayer stopped its development
activities and had fewer sales several years before the years at
issue as establishing that the taxpayer changed its holding
purpose). Second, we may consider the holding purpose of Hancock
Enterprises in deciding why petitioner held the lots. See
Parkside, Inc. v. Commissioner, 571 F.2d 1092, 1096 (9th Cir.
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