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910 (5th Cir. 1969); Cottle v. Commissioner, supra at 487;
Raymond v. Commissioner, T.C. Memo. 2001-96; 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 these factors may aid the finder of fact in
determining, on the entire record, the taxpayer’s primary purpose
for holding property, they have no independent significance and
individual comment on each factor is not necessary or required.
Cottle v. Commissioner, supra at 487-489; see also Suburban
Realty Co. v. United States, supra at 177-179; Hay v.
Commissioner, T.C. Memo. 1992-409.
Petitioner and Mrs. Wood did not purchase and hold the
Virginia house, the New Jersey house, or the Florida house for
sale to customers in the ordinary course of a trade or business.
Petitioner and Mrs. Wood purchased the Virginia house in 1974.
They resided in that house until 1977 when they moved to New
Jersey after petitioner retired from the military. Petitioner
and Mrs. Wood sold the Virginia house and purchased a new
residence, the New Jersey house. They lived in the New Jersey
house until 1990 when they moved into their next residence, the
newly constructed Florida house. After the contract for sale of
the New Jersey house fell through, they rented that house on a
month-to-month basis until it was sold. To satisfy their
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