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appreciation in the value of the land, the general rule of
the regulations is applicable in this case. See Hoyle v.
Commissioner, supra. Under that rule all facts and
circumstances must be taken into account in determining
whether there is a single activity. Sec. 1.183-1(d)(1),
Income Tax Regs. On the basis of all the facts and circum-
stances of this case, we find that all of petitioners'
activities, including holding the land, should be treated
as a single activity for section 183 purposes.
Factors Relating to Petitioners' Farm Activity
Section 1.183-2(b), Income Tax Regs., lists the
following factors relevant to determining whether an
activity is engaged in for profit: (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) expectation that the assets used in the activity may
appreciate in value; (5) the success of the taxpayer in
carrying on 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 are earned; (8) the financial status of the taxpayer;
and (9) elements of personal pleasure or recreation
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