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Commissioner, T.C. Memo. 1973-82 (cited by Williford v.
Commissioner, supra). This factor suggests property segregated
from other property may indicate some assets are held for
investment while others are held for sale.
In Williford, the Court found that the paintings held as
inventory were kept in a location separate from those held for
investment. While the classic cars were physically segregated
from the new and used cars, we find the physical segregation of
the cars of no moment. A dealership could have numerous physical
locations. The fact remains that the classic cars were on
display to the public at all times in contrast to the paintings
the taxpayer held in his home that were not on display to the
public. Moreover, the classic cars were held separately in
buildings on the Galveston property because they required
protection from the elements, unlike the new and used cars.
Nor do we find segregation of the cars for book purposes
significant. Petitioner explained that it grouped the classic
cars as “other assets” because “current assets” were those that
could be converted to cash within a year. Because the classic
cars were not typically sold within a year, they were listed
under “other assets.” This method is consistent with generally
accepted accounting principles.
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