David Taylor Enterprises, Inc. & Subsidiaries - Page 18

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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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