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The existence of the required profit objective is determined
by the objective of the entity which has control over the
activity under scrutiny. Drobny v. Commissioner, supra at 1341.
Thus, the existence of a profit objective of a partnership is
determined at the partnership level, Agro Science Co. v.
Commissioner, supra at 576; the existence of a profit objective
of a joint venture is determined at the joint venture level,
Brannen v. Commissioner, 78 T.C. 471, 501-505 (1982), affd. 722
F.2d 695 (11th Cir. 1984).
Resolution of whether a taxpayer engages in an activity with
the requisite intention of making a profit is one of fact to be
resolved on the basis of all the facts and circumstances. Agro
Science Co. v. Commissioner, supra at 576; Hulter v.
Commissioner, 91 T.C. 371, 393-394 (1988); Drobny v.
Commissioner, supra at 1341. In making this determination, more
weight must be given to the objective facts than to the
taxpayer's mere after-the-fact statements of intent. Agro
Science Co. v. Commissioner, supra at 576; Beck v. Commissioner,
85 T.C. 557, 570 (1985); sec. 1.183-2(a), Income Tax Regs.
Petitioner made no independent investigation of Century
Concepts prior to his participation. He did not obtain the
services of any professional to review the leasing documents
before signing. Petitioner failed to obtain any independent
appraisals of the masters and, in fact, never received a copy of
one master and never opened the copy he did have of the other.
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