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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 given to objective facts than to self-serving
statements of 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 a nonexclusive list of nine 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). No single factor is determinative
of the issue, however. Golanty v. Commissioner, 72 T.C. 411
(1979), affd. without published opinion 647 F.2d 170 (9th Cir.
1981). The nine factors set forth under section 1.183-2(b),
Income Tax Regs., are: (1) The manner in which the taxpayer
carries on the activity; (2) the expertise of the taxpayer or his
advisers; (3) the time and effort expended by the taxpayer in
carrying on other similar or dissimilar activities; (4) the
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