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Sec. 162(a). The Supreme Court has stated that "to be engaged in
a trade or business, * * * the taxpayer's primary purpose for
engaging in the activity must be for income or profit. A
sporadic activity, a hobby, or an amusement diversion does not
qualify." Commissioner v. Groetzinger, 480 U.S. 23, 35 (1987).
The taxpayer bears the burden of showing he had the required
profit motive. Rule 142(a); Golanty v. Commissioner, 72 T.C.
411, 426 (1979), affd. without published opinion 647 F.2d 170
(9th Cir. 1981).
Whether a taxpayer has the required profit motive is to be
determined on the basis of all the facts and circumstances of
each case. Allen v. Commissioner, 72 T.C. 28, 34 (1979). Some
of the relevant factors to be considered in determining whether
an activity is engaged in for profit for the purposes of section
162 are: (1) The manner in which the taxpayer carries on the
activity; (2) the expertise of the taxpayer or his 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) whether
elements of personal pleasure or recreation are involved. See
Thomas v. Commissioner, 792 F.2d 1256, 1258 (4th Cir. 1986),
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