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affg. 84 T.C. 1244 (1985); Carter v. Commissioner, 645 F.2d 784,
787 (9th Cir. 1981), affg. T.C. Memo. 1978-202; Cooper v.
Commissioner, 88 T.C. 84, 107-109 (1987); Seaman v. Commissioner,
84 T.C. 564, 589 (1985); Gestrich v. Commissioner, 74 T.C. 525,
529 (1980), affd. without published opinion 681 F.2d 805 (3d Cir.
1982); Engdahl v. Commissioner, 72 T.C. 659, 666 (1979);
Churchman v. Commissioner, 68 T.C. 696, 702 (1977); Eppler v.
Commissioner, 58 T.C. 691, 699 (1972), affd. without published
opinion 486 F.2d 1406 (7th Cir. 1973); Purdy v. Commissioner, 12
T.C. 888, 892 (1949); sec. 1.183-2(b), Income Tax Regs. No one
factor is controlling. Dunn v. Commissioner, 70 T.C. 715, 720
(1978), affd. 615 F.2d 578 (2d Cir. 1980). While the focus of
the test is on the subjective intention of the taxpayer, greater
weight is given to the objective facts than to the taxpayer's
mere statement of his or her intent. Dreicer v. Commissioner, 78
T.C. 642, 645 (1982), affd. without published opinion 702 F.2d
1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs.
We find the following facts to be significant in our
determination of whether petitioner had a profit motive: (1)
Petitioner failed to carry on the activity in a businesslike
manner; (2) petitioner did not maintain adequate books and
records for his real estate activity or account to Ms. Choe for
any amounts spent to improve her properties; (3) petitioner had
no income from the activity (petitioner testified that he made no
profit on the sale of the 11031 Burnet property, and he never
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