Pool, et al. v. Comr., T.C. Memo. 2014-3

(gain from sale of LLC (taxed as a partnership) real estate characterized by petitioner as long-term capital gain; court upheld IRS determination that proceeds of sale should have been reported as ordinary income because real property held for sale to customers in ordinary course of business; evidence showed that property acquired for development and sale and petitioner couldn't show that sales not frequent and substantial; over 80 purchasers sought after by petitioner).