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petitioner's statement of her intent. Sec. 1.183-2(a), Income
Tax Regs. Petitioner bears the burden of showing she engaged in
her tutoring activity with the actual and honest objective of
realizing a profit. Rule 142(a); Golanty v. Commissioner, supra
at 426.
The following factors, which are nonexclusive, should be
considered in the determination of whether an activity is engaged
in for profit: (1) The manner in which the taxpayer carried on
the activity; (2) the expertise of the taxpayer or his or her
advisers; (3) the time and effort expended by the taxpayer in
carrying on the activity; (4) the expectation that 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 of personal pleasure or recreation. Sec. 1.183-2(b),
Income Tax Regs. No one factor is determinative in and of
itself, and a profit objective does not hinge on the number of
factors satisfied. Id.
Petitioner did not carry on her tutoring activity in a
businesslike manner. Sec. 1.183-2(b)(1), Income Tax Regs.
Petitioner did not maintain a separate bank account for the
activity. Neither did she produce any books or records she might
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