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The taxpayer’s primary purpose for holding the property must

be determined by reference to his purpose “at some point before

he

decided

to

make

the

sale”.

Suburban

Realty

Co.

v.

United

States,

615

F.2d

171,

182

(5th

Cir.

1980).

Earlier

events

may

be

considered in deciding what the taxpayer’s primary purpose was at

the

time

of

sale.

The

ownership

and

maintenance

of

the

property

must relate primarily to a business, rather than a social or

personal,

purpose.

Intl.

Artists,

Ltd.

v.

Commissioner,

55

T.C.

94, 104 (1970); Chapman v. Commissioner, 48 T.C. 358, 366 (1967).

Over the years, courts have considered a variety of factors

in determining the taxpayer’s primary purpose for holding

property, including (1) the taxpayer’s purpose in acquiring the

property and the duration of his ownership, (2) the purpose for

which the property was subsequently held; (3) the taxpayer’s

everyday business and the relationship of realty income to total

income, (4) the frequency, continuity, and substantiality of

sales of property, (5) the extent of developing and improving the

property to increase sales, (6) the extent to which the taxpayer

used advertising, promotion, or other activities to increase

sales, (7) the use of a business office for the sale of

property, (8) the character and degree of supervision or control

the taxpayer exercised over any representative selling the

property, and (9) the time and effort the taxpayer habitually

devoted

to

the

sales.

United

States

v.

Winthrop,

417

F.2d

905,

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