- 13 -
Commissioner, supra at 46; Golanty v. Commissioner, supra at 426;
sec. 1.183-2(a), Income Tax Regs.
Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of factors to be considered in determining
whether an activity is engaged in for profit. No single factor
is determinative. Keanini v. Commissioner, supra at 47; Taube v.
Commissioner, 88 T.C. 464, 479-480 (1987); sec. 1.183-2(b),
Income Tax Regs.
Taking into account the factors set forth in section 1.183-
2(b), Income Tax Regs., and based on the record as a whole, we
conclude that the charter activity was not an activity entered
into for profit, and we have so found.
C. Petitioner Had No Objective To Make a Profit
The regulations provide that “Although a reasonable
expectation of profit is not required, the facts and
circumstances must indicate that the taxpayer entered into the
activity * * * with the objective of making a profit.” Sec.
1.183-2(a), Income Tax Regs.
We conclude that, although petitioner certainly would have
liked Ballard Marine to make a profit, that was not his objective
in organizing and operating Ballard Marine.
In determining petitioner’s objective in organizing and
operating Ballard Marine, we have the benefit of neither a
statement of corporate purpose (in Ballard Marine’s articles of
incorporation) nor a formal business plan. Nevertheless,
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