- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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