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| | Property Held for Resale |
 | | While, in general, most properties owned by developers, builders and people who perform rehabilitation work will probably be considered to be held primarily for sale and may not be allowed exchange treatment, the courts look to the intent of the taxpayer in determining whether the property qualifies for exchange treatment. |
 | | The courts measure the taxpayer's intent at the point of the date of the sale or exchange of the property and not necessarily to the pre-exchange or post-exchange use of the property. |
 | | The next factor the courts consider is the extent of the taxpayer's development activities, such as subdividing the property, adding streets, roads, sewers and utility services, obtaining a rezoning of the property and renovating the property. |
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