- 17 - 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 dispositive. 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011