David Taylor Enterprises, Inc. & Subsidiaries - Page 17

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          less than 2 years, one was held less than 4 years, and one was              
          held less than 10 years.  None of the classic cars were held for            
          as long as the periods set forth in Williford.                              
               Moreover, in Williford, the paintings did not require work             
          akin to the extensive time and effort the dealership devoted to             
          refurbishing and restoring the classic cars.  The attendant                 
          length of ownership is therefore longer in the case of value-               
          added classic cars.  In comparison, the dealership’s new and used           
          cars were held shorter periods for readily apparent reasons.                
          Respondent’s argument comparing the shorter periods for the new             
          and used cars vis-a-vis the classic cars, therefore, is not                 
               The value of the new and used cars, as petitioner explained,           
          depreciated quickly, demanding quicker turnover.  In contrast,              
          the classic cars appreciated in value over time and,                        
          consequently, did not necessitate the same rapid turnover period.           
          We find, therefore, that the holding period for the classic cars            
          is consistent with finding the dealership held the classic cars             
          for sale.  This factor favors petitioner.                                   
               4.  Segregation of Classic Cars From New and Used Cars                 
               Property held for sale and property held for investment must           
          be separately identified.  Scheuber v. Commissioner, 371 F.2d               
          996, 998-999 (7th Cir. 1967), revg. T.C. Memo. 1966-107 (cited by           
          Williford v. Commissioner, supra); Frank H. Taylor & Son, Inc. v.           

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