-21-
1977) (in deciding the purpose for which the taxpayer held
property, the court considered the holding purpose of the
taxpayer's shareholders' father, from whom the shareholders
inherited the property), revg. T.C. Memo. 1975-14.
B. Conclusion
We conclude that petitioner held the eight lots she sold
during the years in issue for sale to customers in the ordinary
course of her trade or business. Petitioner's sales were
frequent, regular, and substantial in the years in issue. She
devoted a sufficient amount of time and effort to selling the
lots. She began to sell the lots when she received them from the
corporation. The fact that petitioner held some of the lots for
a substantial period of time before she sold them does not in
itself establish that she held the lots for investment.
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Last modified: May 25, 2011