Flood v. Comr., T.C. Memo. 2012-243

(petitioner, day-trader in stocks, also operated real estate activity with wife involved in buying and selling vacant lots; over seven-year period, couple purchased over 250 lots but sold only approximately 50 lots and gave some to a church; petitioners determined to be dealers in real estate with profits subject to tax at ordinary rates and reported on Schedule C; under multi-factor analysis, sale of lots generated large gains; charitable donation reduced because taxpayer was dealer and, as such, charitable donation deduction measured by cost of property rather than market value at time of donation).