Prepare a memo to file and client letter for the following research problem:

John Dehner owns some plots of land around Navasota, TX$.$ He acquired the plots of land at various times in the last $25$ years. Assume that Dehner subdivides into lots one of the properties he owns. He then has water, sewer, natural gas, and electricity hookups put in each lot and paves new streets. Dehner would like to know if he can treat the gains on the sales of such properties as capital gains.

In your research, you should consider IRC Sections $1221$ and $1237.$ Also, see Reg Sec $1\mathrm{.}1237-1.$ Finally, you should find a relevant Tax Court case decided between $1985$ and $1999$ to help you come up with your output.