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A taxpayer holds property for investment if he or she had a
substantial investment intent in acquiring and holding the
property. See Recklitis v. Commissioner, 91 T.C. 874, 907
(1988); Polakis v. Commissioner, 91 T.C. 660, 668 n.8 (1988);
Miller v. Commissioner, 70 T.C. 448, 455-456 (1978);
W. W. Windle Co. v. Commissioner, 65 T.C. 694, 713 (1976). A
taxpayer lacks a substantial investment intent if the taxpayer
acquires a business solely to provide employment for himself.
See Boseker v. Commissioner, T.C. Memo. 1986-353; Schanhofer v.
Commissioner, T.C. Memo. 1986-166.
Petitioner bought the nursing homes to provide self-
employment income for himself and employment for his former
spouse. About 97 percent of petitioner’s income in 1993 and 1994
was from the nursing homes. He hoped to sell the nursing homes
for a profit when he retired, but any investment motive was
remote or nonexistent. Thus, this case is unlike Miller v.
Commissioner, 70 T.C. 448, 453, 457 (1978), and Malone v.
Commissioner, T.C. Memo. 1996-408, in which the taxpayers bought
a controlling interest in the stock of businesses predominantly
as an investment. We conclude that petitioner did not have a
substantial investment intent when he bought and held the nursing
homes, that he did not hold the nursing homes for investment, and
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