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relevant facts and circumstances. Hulter v. Commissioner, supra
at 393; Golanty v. Commissioner, 72 T.C. 411, 426 (1979), affd.
in an unpublished opinion 647 F.2d 170 (9th Cir. 1981). The
burden of proving such objective is on petitioner. Rule 142(a);
Welch v. Helvering, 290 U.S. 111 (1933). Greater weight is given
to objective facts than to a taxpayer's statement of intent.
Beck v. Commissioner, supra at 570; Thomas v. Commissioner, 84
T.C. 1244, 1269 (1985), affd. 792 F.2d 1256 (4th Cir. 1986); sec.
1.183-2(a), Income Tax Regs.
Section 1.183-2(b), Income Tax Regs., provides a non-
exclusive list of factors which should be considered in
determining whether an activity is engaged in with the requisite
profit objective. The nine factors are: (1) The manner in which
the taxpayer carries 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
the assets used by the taxpayer 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
losses with respect to the activity; (7) the amount of occasional
profits, if any, which are earned; (8) the financial status of
the taxpayer; and (9) whether elements of personal pleasure or
recreation are involved. No single factor, nor the existence of
even a majority of the factors, is controlling, but rather it is
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