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look to the taxpayer’s intent at the time he disposes of the
property.4 See Cottle v. Commissioner, 89 T.C. 467, 487 (1987).
Generally, we look to the following factors when making such
evaluation: (1) The taxpayer’s purpose for initially acquiring
the property; (2) the purpose for which the property was
subsequently held; (3) the extent to which the taxpayer made
improvements to the property; (4) the frequency, number, and
continuity of sales; (5) the extent and nature of the taxpayer’s
efforts to sell the property; (6) the character and degree of
supervision or control exercised by the taxpayer over any
representative selling the property; (7) the extent and nature of
the transactions involved; and (8) the taxpayer’s everyday
business and the relation of realty income to total income. See
id. at 487; Neal T. Baker Enters., Inc. v. Commissioner, T.C.
Memo. 1998-302; Nadeau v. Commissioner, T.C. Memo 1996-427;
Tollis v. Commissioner, T.C. Memo. 1993-63, affd. without
published opinion 46 F.3d 1132 (6th Cir. 1995). Although no
single factor is determinative, the combination of several
factors supporting a particular result is sufficient for us to
decide whether a taxpayer held property for sale to customers in
the ordinary course of a trade or business. See Cottle v.
Commissioner, supra at 488.
4 We may, however, consider earlier events to decide what
the taxpayer’s purpose was at the time of the sale. See Cottle
v. Commissioner, 89 T.C. 467, 487 (1987).
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