Geraldine H. Pearson - Page 9

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          profit.  These factors are:  (1) The manner in which the taxpayer           
          conducts the activity; (2) the expertise of the taxpayer or his             
          advisers; (3) the time and effort expended by the taxpayer in               
          carrying on the activity; (4) the success of the taxpayer in                
          carrying on other similar or dissimilar activities; (5) the                 
          taxpayer's history of income or loss with respect to the                    
          activity; (6) the amount of occasional profit, if any, which is             
          earned; (7) the expectation that the assets used in the activity            
          may appreciate in value; (8) the financial status of the                    
          taxpayer; and (9) whether elements of personal pleasure or                  
          recreation are involved.  No single factor controls.  Abramson v.           
          Commissioner, 86 T.C. 360, 371 (1986); Golanty v. Commissioner,             
               1.  Manner in Which the Taxpayer Conducts the Activity                 
               Conducting an activity similarly to comparable businesses              
          which are profitable may indicate that a taxpayer engaged in the            
          activity for profit.  Engdahl v. Commissioner, 72 T.C. 659, 666-            
          667 (1979); sec. 1.183-2(b)(1), Income Tax Regs.  Maintenance of            
          complete and accurate records may indicate that the taxpayer has            
          a profit objective.  Elliott v. Commissioner, 90 T.C. 960, 971-             
          972 (1988), affd. without published opinion 899 F.2d 18 (9th Cir.           
               Petitioner contends that her activities were businesslike              
          because she maintained a separate ledger for her farm, made                 
          notations on her checks indicating that they were for business              
          expenses, and had a C.P.A. prepare her tax returns.  We disagree.           

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