-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