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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
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.
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