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The taxpayer’s primary purpose for holding the property must
be determined by reference to his purpose “at some point before
he decided to make the sale”. Suburban Realty Co. v. United
States, 615 F.2d 171, 182 (5th Cir. 1980). Earlier events may be
considered in deciding what the taxpayer’s primary purpose was at
the time of sale. The ownership and maintenance of the property
must relate primarily to a business, rather than a social or
personal, purpose. Intl. Artists, Ltd. v. Commissioner, 55 T.C.
94, 104 (1970); Chapman v. Commissioner, 48 T.C. 358, 366 (1967).
Over the years, courts have considered a variety of factors
in determining the taxpayer’s primary purpose for holding
property, including (1) the taxpayer’s purpose in acquiring the
property and the duration of his ownership, (2) the purpose for
which the property was subsequently held; (3) the taxpayer’s
everyday business and the relationship of realty income to total
income, (4) the frequency, continuity, and substantiality of
sales of property, (5) the extent of developing and improving the
property to increase sales, (6) the extent to which the taxpayer
used advertising, promotion, or other activities to increase
sales, (7) the use of a business office for the sale of
property, (8) the character and degree of supervision or control
the taxpayer exercised over any representative selling the
property, and (9) the time and effort the taxpayer habitually
devoted to the sales. United States v. Winthrop, 417 F.2d 905,
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