Melissa S. Spranger - Page 8




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          Although a reasonable expectation of profit on taxpayer's part is           
          not required, the profit objective must be bona fide, as                    
          determined from a consideration of the surrounding facts and                
          circumstances.  Keanini v. Commissioner, supra at 46; Dreicer v.            
          Commissioner, supra at 645; Golanty v. Commissioner, 72 T.C. 411,           
          426 (1979), affd. without published opinion 647 F.2d 170 (9th               
          Cir. 1981); Bessenyey v. Commissioner, 45 T.C. 261, 274 (1965),             
          affd. 379 F.2d 252 (2d Cir. 1967).                                          
               Whether petitioner engaged in her dog breeding activity with           
          an actual and honest objective of realizing a profit must be                
          redetermined year-to-year, taking into account all of the                   
          relevant facts and circumstances.  Golanty v. Commissioner, supra           
          at 426; sec. 1.183-2(a) and (b), Income Tax Regs.  More weight is           
          given to objective facts than to petitioner's statement of her              
          intent.  Engdahl v. Commissioner, 72 T.C. 659, 666 (1979); sec.             
          1.183-2(a), Income Tax Regs.  Respondent's determinations with              
          respect to other years, if any, may be taken into account but are           
          not conclusive.                                                             
               The following factors, which are nonexclusive, should be               
          considered in the determination of whether an activity is engaged           
          in for profit:  (1) The manner in which the taxpayer carried on             
          the activity; (2) the expertise of the taxpayer or his or her               
          advisers; (3) the time and effort expended by the taxpayer in               
          carrying on the activity; (4) the expectation that assets used in           
          the activity may appreciate in value; (5) the success of the                
          taxpayer in carrying on other similar or dissimilar activities;             

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