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[trade or business] or under paragraph (1) or (2) of section 212
[expenses for the production of income]". For a deduction to be
allowed under section 162 or section 212(1) or (2), taxpayers
must establish that they engaged in the activity with an actual
and honest objective of making an economic profit independent of
tax savings. Antonides v. Commissioner, 91 T.C. 686, 693-694
(1988), affd. 893 F.2d 656 (4th Cir. 1990); Dreicer v.
Commissioner, 78 T.C. 642, 644-645 (1982), affd. without opinion
702 F.2d 1205 (D.C. Cir. 1983). Their expectation of profit need
not have been reasonable; however, they must have entered into
the activity, or continued it, with the objective of making a
profit. Hulter v. Commissioner, 91 T.C. 371, 393 (1988); sec.
1.183-2(a), Income Tax Regs.
The burden is on petitioners to show error in respondent's
determination that the treasure hunting activity was not engaged
in for profit. Rule 142(a). Whether the requisite profit
objective exists is determined by looking to all the surrounding
facts and circumstances. Keanini v. Commissioner, 94 T.C. 41, 46
(1990); sec. 1.183-2(b), Income Tax Regs. Greater weight is
given to objective facts than to a taxpayer's mere statement of
intent. Thomas v. Commissioner, 84 T.C. 1244, 1269 (1985); sec.
1.183-2(a), Income Tax Regs.
Section 1.183-2(b), Income Tax Regs., provides a list of
factors to be considered in the evaluation of a taxpayer's profit
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