- 6 -
Helvering, 292 U.S. 435, 440 (1934). Taxpayers also have the
burden of substantiation. Hradesky v. Commissioner, 65 T.C. 87
(1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976).
Petitioner's rental expenses are deductible under sections
162 or 212 only if his use of the properties constituted an
activity engaged in for profit. Sec. 183(a). The test to
determine whether an activity is engaged in for profit is whether
the individual engaged in the activity with the "actual and
honest objective of making a profit." Dreicer v. Commissioner,
78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205
(D.C. Cir. 1983). The taxpayer's expectation of earning a profit
need not be reasonable, but the taxpayer must establish that the
activities were continued with a bona fide profit objective.
Dreicer v. Commissioner, supra; Hager v. Commissioner, 76 T.C.
759, 784 (1981); sec. 1.183-2(a), Income Tax Regs. Whether the
taxpayer had such an objective must be determined by reference to
all the surrounding facts and circumstances, and greater weight
is given to such facts than to the taxpayer's statement of
intent. Dreicer v. Commissioner, supra. The regulations set
forth various factors to consider. Sec. 1.183-2(b), Income Tax
Regs.
Petitioner substantiated $3,218.06 of real estate taxes paid
in 1991 for the Church Road, Charlotte Street, and Langdon Grove
properties. Petitioner has produced no records or history of
income for the Church Road, Charlotte Street, and Langdon Grove
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