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910 (5th Cir. 1969); Cottle v. Commissioner, supra at 487;

Raymond v. Commissioner, T.C. Memo. 2001-96; Neal T. Baker

Enters., Inc. v. Commissioner, T.C. Memo. 1998-302; Nadeau v.

Commissioner, T.C. Memo. 1996-427; Tollis v. Commissioner, T.C.

Memo. 1993-63, affd. without published opinion 46 F.3d 1132 (6th

Cir.

1995).

Although

these

factors

may

aid

the

finder

of

fact

in

determining, on the entire record, the taxpayer’s primary purpose

for holding property, they have no independent significance and

individual comment on each factor is not necessary or required.

Cottle v. Commissioner, supra at 487-489; see also Suburban

Realty Co. v. United States, supra at 177-179; Hay v.

Commissioner, T.C. Memo. 1992-409.

Petitioner and Mrs. Wood did not purchase and hold the

Virginia house, the New Jersey house, or the Florida house for

sale to customers in the ordinary course of a trade or business.

Petitioner and Mrs. Wood purchased the Virginia house in 1974.

They resided in that house until 1977 when they moved to New

Jersey

after

petitioner

retired

from

the

military.

Petitioner

and Mrs. Wood sold the Virginia house and purchased a new

residence,

the

New

Jersey

house.

They

lived

in

the

New

Jersey

house until 1990 when they moved into their next residence, the

newly

constructed

Florida

house.

After

the

contract

for

sale

of

the New Jersey house fell through, they rented that house on a

month-to-month

basis

until

it

was

sold.

To

satisfy

their

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