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an activity is engaged in for profit. These factors are: (1)
The manner in which the taxpayers carry on the activity; (2) the
expertise of the taxpayers or their advisers; (3) the time and
effort expended by the taxpayers in carrying on the activity; (4)
the expectation that assets used in the activity may appreciate
in value; (5) the success of the taxpayers in carrying on other
activities; (6) the taxpayers' history of income or losses with
respect to the activity; (7) the amount of occasional profit, if
any, which is earned; (8) the financial status of the taxpayers;
(9) whether elements of personal pleasure or recreation are
involved. Not all of these factors are necessarily applicable in
every case. Brannen v. Commissioner, 722 F.2d 695, 704 (11th
Cir. 1984), affg. 78 T.C. 471 (1982); Taube v. Commissioner,
supra; Abramson v. Commissioner, 86 T.C. 360, 371 (1986); Allen
v. Commissioner, 72 T.C. 28, 34 (1979). No one factor nor a
majority of the factors is necessarily determinative, nor do we
reach our conclusion by simply counting the factors that support
each party's position. Keanini v. Commissioner, 94 T.C. 41, 47
(1990); Taube v. Commissioner, supra at 480; Dunn v.
Commissioner, supra at 720.
The Manner in Which the Taxpayers Carry On the Activity.
The fact that a taxpayer generally carries on an activity, in a
businesslike manner and maintains complete and accurate books and
records may be indicative of a profit motive. Similarly, where
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