Recent court decisions are reminders that land may not always be a capital asset that gives rise to a capital gain when sold. Land may also be held for sale to customers in the ordinary course of business, in which case gain on the sale of the land will be ordinary income.
Source: http://feedproxy.google.com/~r/AICPA_TaxAdvisor/~3/s10Vg_D_ZYc/Tax_Clinic_07.aspx
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