Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 19

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               Section 1.183-2(b), Income Tax Regs., provides a list of               
          factors to be considered in the evaluation of a taxpayer's profit           
          objective:  (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 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 from the activity; (7) the amount of occasional            
          profits, if any, from the activity; (8) the financial status of             
          the taxpayer; and (9) elements of personal pleasure or                      
          recreation.  The number of factors for or against the taxpayer is           
          not necessarily determinative, but rather all facts and                     
          circumstances must be taken into account, and more weight may be            
          given to some factors than to others.  Cf. Dunn v. Commissioner,            
          70 T.C. 715, 720 (1978), affd. 615 F.2d 578 (2d Cir. 1980).  This           
          list is nonexclusive, and no single factor or even a majority of            
          factors necessarily controls.  Abramson v. Commissioner, 86 T.C.            
          360, 371 (1986); sec. 1.183-2(b), Income Tax Regs.                          
               After weighing all of the objective factors coupled with               
          petitioner's statements of intent, we conclude that the                     
          Dickersons were not engaged in the tree farming activity for                
          profit.  There is objective evidence which shows that the                   
          Dickersons did not have a profit objective in carrying on the               
          tree farming business:  The Dickersons gave away many trees; no             

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