- 25 - Respondent had the burden to prove by a preponderance of the evidence that the classic cars were not held for sale. He did not meet that burden. We conclude that the dealership’s classic cars were held for sale and hence qualify for an exception from capital asset status under section 1221(a)(1). Accordingly, we do not sustain respondent’s determination. Decision will be entered for petitioner.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Last modified: May 25, 2011