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(4) the expectation that assets used in the activity may appreci-
ate in value, (5) the success of the taxpayer in carrying on
other similar or dissimilar activities, (6) the taxpayer's
history of income or loss 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) the extent to which
elements of personal pleasure or recreation are involved. Sec.
1.183-2(b), Income Tax Regs. The list of factors in the regula-
tions is not exclusive, and other factors may be considered in
determining whether an activity is engaged in for profit. No
single factor is dispositive. E.g., Golanty v. Commissioner,
supra at 426; sec. 1.183-2(b), Income Tax Regs. The determina-
tion of a profit objective does not depend on counting the number
of factors that support each party's position. E.g., Dunn v.
Commissioner, supra at 720; sec. 1.183-2(b), Income Tax Regs.
Petitioner contends that (1) during 1989, 1990, and 1991, he
was engaged in his horse activity for profit within the meaning
of section 183; (2) during 1990 and 1991, he was engaged in his
cattle activity for profit within the meaning of section 183; and
(3) during 1990 and 1991, his horse activity and his cattle
activity constituted one activity for purposes of that section.
Respondent disagrees with each of petitioner's contentions.
We turn first to whether, during 1990 and 1991, petitioner's
horse activity and cattle activity constituted one activity or
two separate activities for purposes of section 183. Section
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