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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 similar or dissimilar activities; (6) the taxpayer's history
of income or losses in the activity; (7) the amount of occasional
profits, if any, that are earned; (8) the financial status of the
taxpayer; and (9) the elements of personal pleasure or
recreation. Westbrook v. Commissioner, supra at 876; sec.
1.183-2(b), Income Tax Regs. None of these nine factors is
dispositive, in and of itself, and a decision does not rest on
the number of factors satisfied. Golanty v. Commissioner, supra
at 426; sec. 1.183-2(b), Income Tax Regs. We assess each factor
with the aid of our common sense, and we bear in mind the insight
that we have gained from a lifetime of experience, as well as our
understanding of how the relevant statutory scheme was meant to
apply to the facts at hand. Ranciato v. Commissioner, 52 F.3d
23, 25-26 (2d Cir. 1995), remanding T.C. Memo. 1993-536.
Bearing these basic principles in mind, we turn to the nine
factors, analyzing and discussing them one at a time.
1. Manner in which the activity is conducted
We consider the manner in which petitioners conducted their
breeding activity. See sec. 1.183-2(b)(1), Income Tax Regs.
Objective facts showing that a taxpayer carries on an activity in
a businesslike manner are indicative of a profit intent. The
same is true with respect to the maintenance of complete and
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