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for profit. No one factor is controlling. Abramson v.
Commissioner, 86 T.C. 360, 371 (1986); Golanty v. Commissioner,
supra at 426. Such relevant factors include (1) the manner in
which the taxpayer carries on the activity; (2) the expertise of
the taxpayer or advisers; (3) the time and effort expended by the
taxpayer in carrying on the activity; (4) the taxpayer's history
of income or loss with respect to the activity; (5) the amount of
occasional profits, if any, that are earned; (6) the financial
status of the taxpayer; and (7) whether elements of personal
pleasure or recreation are involved.
Petitioner contends that the nursery activity was a trade or
business that he operated for profit. But, it is perfectly
obvious that when all of the costs that petitioner associates
with the Long Beach properties and the travel to and from that
area are considered as expenses of the nursery, the venture could
never produce a profit, and there could not have been an actual
and honest objective of a profit. Indeed, even if petitioner
could have produced 5,000 pots of tulips (the "maximum profit"),
he still would not have made a profit.3
In reality, however, many of the expenses that petitioner
attempts to associate with the nursery are expenses of a
nonbusiness activity, i.e., a second home to be used on weekends,
3 Indeed, while some of the factors listed in sec. 1.183-
2(b), Income Tax Regs., may be neutral, none of those factors
really favor petitioner's position.
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