Cable Vista was continuously involved in ‘manufacture, construction, or production of property’ in that it was continuously in the process of laying cables and acquiring and connecting new customers to its system. The creation of both tangible property (the cable system) and intangible property (such as franchises and goodwill) are within the reach of section 341. Computer Sciences Corp., 63 T.C. 327, 346-347 (1974); FTS Associates, Inc., 58 T.C. 207 (1972). Petitioner argues that section 341 is inapplicable to a business where production is continuous, but cites no authority, nor do we know of any, that would support this proposition.

Petitioner contends that any manufacturing, construction, or production of its real property occurred prior to the time when it first had a view toward liquidation of its assets to its shareholders. E. g., F. T. S. Associates, 58 T.C. 207 (1972). Respondent takes the position that petitioner's activities of subdividing and surveying the parcels sold, dedicating rights-of-way for access roads, and the construction of the Powell road constituted construction and such construction was continuous up to, including, and after the existence of the view toward distribution.