Bud Raymond - Page 8

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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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