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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,
supra.
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.
1990).
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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