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taxpayer engages in an activity for profit if he entered into the
activity with the actual and honest objective of making a profit.
Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without
published opinion 702 F.2d 1205 (D.C. Cir. 1983). The taxpayer's
expectation of profit need not be reasonable, but he or she must
have a good faith objective of making a profit. Allen v.
Commissioner, 72 T.C. 28, 33 (1979); sec. 1.183-2(a), Income Tax
Regs.
The determination of whether a taxpayer conducted the
activity for profit is made based on the facts and circumstances
of the case. Golanty v. Commissioner, 72 T.C. 411, 426 (1979),
affd. without published opinion 647 F.2d 170 (9th Cir. 1981).
Although the purpose of the inquiry is to ascertain the
taxpayer's subjective intent, greater weight is given to
objective facts than to the taxpayer's statements of intent.
Beck v. Commissioner, 85 T.C. 557, 570 (1985); sec. 1.183-2(a),
Income Tax Regs. Petitioners bear the burden of proving they
intended to make a profit. Beck v. Commissioner, supra at 570.
Section 1.183-2(b), Income Tax Regs., sets forth a
nonexclusive list of nine factors designed to provide guidance to
courts in analyzing a taxpayer's profit objective. See
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
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