David Taylor Enterprises, Inc. & Subsidiaries - Page 25

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               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.                          































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Last modified: May 25, 2011