Lee W. Yates and Wendy S. Yates - Page 7

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          upon a taxpayer's mere statements of intent.  Dreicer v.                    
          Commissioner, supra at 645.  Nevertheless, there is no                      
          requirement that the taxpayer reasonably expect profits from the            
          activity in question.  Elliott v. Commissioner, 90 T.C. 960, 970            
          (1988), affd. without published opinion 899 F.2d 18 (9th Cir.               
          1990).  Section 1.183-2(b), Income Tax Regs., provides nine                 
          factors to be considered when determining whether an activity is            
          engaged in for profit.  These are:  (1) The manner in which the             
          taxpayer carries 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              
          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) the elements of personal pleasure or                  
          recreation that may be present.  No single factor is controlling.           
          Abramson v. Commissioner, 86 T.C. 360, 371 (1986); sec. 1.183-              
          2(b), Income Tax Regs.  We will separately discuss each factor.             
               1.   The Manner in Which Petitioners Carried On the Horse-             
                    Breeding Activity                                                 
               Taxpayers who carry on the activity in question in a                   
          businesslike manner, and maintain complete and accurate books and           
          records, are more likely to establish that the activities in                





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