Margaret Hancock - Page 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