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classic cars specifically and the dealership in general, and to
cover overhead.
We found the testimony that the classic cars were acquired
as inventory to be honest, forthright, and credible. This factor
favors petitioner.
6. Sales and Advertising Effort
Sales and advertising efforts indicate the assets are held
for sale, not investment. Respondent argues that the dealership
did not advertise the classic cars for sale and compares the
advertising strategies the dealership used to market the new and
used cars with the less overt methods the dealership used to
market the classic cars. Again, we find this analogy artificial.
The holding period was shorter for new and used cars, and the
advertising methods consequently more immediate. The dealership
could be selective in its sales so long as its activity was
consistent, overall, with its treatment of the classic cars as
inventory for sale.
Petitioner argues that the dealership used various
advertising methods to market the classic cars for sale. These
included entering the cars in auctions and auto shows, displaying
the cars at numerous events frequented by wealthy individuals,
hosting events at the Galveston property for wealthy car
enthusiasts, designing and printing brochures featuring the cars,
arranging for newspaper and magazine articles about the cars,
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