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published opinion 702 F.2d 1205 (D.C. Cir. 1983). Respondent's
determination is presumptively correct, and petitioner bears the
burden of proving his profit objective. Rule 142(a). Petitioner
need not, however, establish that his profit objective was
reasonable. Dreicer v. Commissioner, supra at 644-645; sec.
1.183-2(a), Income Tax Regs. Profit in this context means
economic profit, independent of tax consequences. Antonides v.
Commissioner, 91 T.C. 686, 694 (1988), affd. 893 F.2d 656 (4th
Cir. 1990). The determination of profit objective is factually
based and requires a consideration of all the surrounding facts
and circumstances. Finoli v. Commissioner, 86 T.C. 697, 722
(1986); sec. 1.183-2(b), Income Tax Regs.
Although the purpose of the inquiry is to ascertain the
taxpayer's subjective intent, greater weight is placed on
objective factors than on the taxpayer's statement of his or her
intent. Beck v. Commissioner, 85 T.C. 557, 570 (1985); sec.
1.183-2, Income Tax Regs. In conducting the profit-objective
analysis, courts have relied on the factors enumerated in the
regulations under section 183. See Hendricks v. Commissioner, 32
F.3d 94 (4th Cir. 1994), affg. T.C. Memo. 1993-396; Independent
Elec. Supply, Inc. v. Commissioner, 781 F.2d 724 (9th Cir. 1986),
affg. Lahr v. Commissioner, T.C. Memo. 1984-472; Elliott v.
Commissioner, 90 T.C. 960 (1988), affd. without published opinion
899 F.2d 18 (9th Cir. 1990). However, no single factor is
determinative of the issue. Golanty v. Commissioner, 72 T.C. 411
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