- 5 -
1991-189; Estate of Perry v. Commissioner, 931 F.2d 1044, 1046
(5th Cir. 1991).
Respondent's position in this case was that petitioners did
not engage in their Amway activities for profit under section
183. In the analysis of a case under section 183, the determina-
tion of whether the requisite profit objective exists depends
upon all the surrounding facts and circumstances. Golanty v.
Commissioner, 72 T.C. 411 (1979), affd. without published opinion
647 F.2d 170 (9th Cir. 1981); sec. 1.183-2(b), Income Tax Regs.
In making this determination, more weight is accorded to objec-
tive facts than to the taxpayer's statement of intent. Siegel v.
Commissioner, 78 T.C. 659, 699 (1982); Dreicer v. Commissioner,
78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205
(D.C. Cir. 1983). Section 1.183-2(b), Income Tax Regs., sets
forth a nonexclusive list of nine factors normally considered in
determining the existence of the requisite profit objective. The
factors 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
were earned; (8) the financial status of the taxpayer; and
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