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on the sale of classic cars during the years at issue are capital
or ordinary losses under section 1221(a).3 Resolution of this
issue depends on whether the classic cars were held primarily for
sale to customers in the ordinary course of business or were held
instead for investment purposes. We hold that petitioner held
the classic cars for sale to customers.
FINDINGS OF FACT
The parties have stipulated some facts. The stipulation of
facts and accompanying exhibits are incorporated by this
reference and are so found.
David Taylor Enterprises
Petitioner is an affiliated group of corporations that files
consolidated income tax returns. See sec. 1501. The common
parent of the affiliated group is David Taylor Enterprises, Inc.
(DTE). Until his death, David Taylor, Sr. (Mr. Taylor) owned all
the shares of DTE. DTE’s principal place of business was
Houston, Texas, at the time it filed the petition.
David Taylor Cadillac
Cars were Mr. Taylor’s love and passion, and he was involved
in the car business throughout his life. When he was a child,
Mr. Taylor’s father was an Oldsmobile-Cadillac dealer in Port
3All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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