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statements of intent. Dreicer v. Commissioner, supra at 645;
Golanty v. Commissioner, supra at 426; sec. 1.183-2(a) and (b),
Income Tax Regs. Section 1.183-2(b), Income Tax Regs., sets
forth the following nonexclusive list of relevant factors to be
considered: (1) The manner in which the taxpayer carries on the
activity; (2) the expertise of the taxpayer or his or her
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 similar or dissimilar activities; (6)
the taxpayer's history of income or loss 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) whether
elements of personal pleasure or recreation are involved. No
single factor is conclusive. Golanty v. Commissioner, supra at
426; sec. 1.183-2(b), Income Tax Regs.
Based on our consideration of the record in the instant
case, we conclude that petitioner has not demonstrated that her
photography activity was carried on with the actual and honest
objective of making a profit. Although the activity had some of
the trappings of a business, those "trappings" are insufficient
to demonstrate that the activity was carried on for profit.
Although petitioner maintained meticulous records, and respondent
has conceded that all of the items of expense noted in her
summaries have been substantiated, such records may represent
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