G. Dastgir and Mary A. Qureshi - Page 13

          the burden to prove that he engaged in the activity with the                
          objective of realizing an economic profit within the meaning of             
          section 183. Surloff v. Commissioner, supra.  If a taxpayer engages         
          in an activity without a profit objective, deductions attributable          
          to the activity are allowed only to the extent of the income                
          derived from the activity.  Sec. 183; Hager v. Commissioner, 76             
          T.C. 759, 781 (1981).                                                       
               Petitioner argues that he had an honest and actual profit              
          objective in purchasing the container.  He also contends that his           
          investment in the container was a business or an enterprise entered         
          into for profit.  Respondent, on the other hand, argues that                
          petitioner’s FoodSource investment was only a means of receiving            
          tax benefits.  We agree with respondent.                                    

          factors: (1) The manner in which the taxpayer carried on the                
          activity; (2) the expertise of the taxpayer or his advisors; (3)            
          the time and effort expended by the taxpayer in carrying on the             
          activity; (4) the expectation that the assets used in the                   
          activity may appreciate in value; (5) the success of the taxpayer           
          in carrying on other similar or dissimilar activities; (6) the              
          taxpayer’s history of income or losses with respect to the                  
          activity; (7) the amount of occasional profits, if any, which are           
          earned; (8) the financial status of the taxpayer; and (9)                   
          elements indicating personal pleasure or recreation.  No single             
          factor, nor the existence of even a majority of the factors, is             
          controlling.  Abramson v. Commissioner, 86 T.C. 360, 371 (1986);            
          Golanty v. Commissioner, 72 T.C. 411, 425-426 (1979), affd.                 
          without published opinion 647 F.2d 170 (9th Cir. 1981); see also            
          Hendricks v. Commissioner, 32 F.3d 94, 98 (4th Cir. 1994), affd.            
          T.C. Memo. 1993-396.  In applying these factors, “courts have               
          universally sought to ascertain the taxpayer’s true intent.”                
          Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without             
          opinion 702 F.2d 1205 (D.C. Cir. 1983).                                     

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