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for-profit activity. Allen v. Commissioner, 72 T.C. 28, 33
(1979).
For purposes of section 183, an activity is not considered
engaged in for profit unless it constitutes an activity entered
into or continued by the taxpayer with an actual and honest or a
good faith objective of making a profit. See Mercer v.
Commissioner, 376 F.2d 708, 710-711 (9th Cir. 1967), revg. T.C.
Memo. 1966-82; Antonides v. Commissioner, 91 T.C. 686, 693-694
(1988), affd. 893 F.2d 656 (4th Cir. 1990); Dreicer v.
Commissioner, 78 T.C. 642, 645 (1982), affd. without published
opinion 702 F.2d 1205 (D.C. Cir. 1983); Barter v. Commissioner,
T.C. Memo. 1991-124, affd. without published opinion 980 F.2d 736
(9th Cir. 1992); Larson v. Commissioner, T.C. Memo. 1986-542,
affd. without published opinion 833 F.2d 1016 (9th Cir. 1987);
Ruben v. Commissioner, T.C. Memo. 1986-260, affd. without
published opinion 852 F.2d 1290 (9th Cir. 1988).
The regulations under section 183 provide a nonexclusive
list of factors to consider in determining whether an activity
was engaged in for profit. Such factors include: (1) The manner
in which the taxpayer carried on the activity; (2) the expertise
of the taxpayer or his advisors; (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; (6) the taxpayer's history of income or
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