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Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of factors to be considered in determining
whether an activity is engaged in for profit. These factors
include: (1) The manner in which the taxpayers carried 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 the assets used in the
activity may appreciate in value; (5) the success of the
taxpayers 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
are earned; (8) the financial status of the taxpayers; and (9)
any elements indicating personal pleasure or recreation.
Although these factors are helpful in ascertaining a taxpayer's
objective in engaging in the activity, no single factor, nor the
existence of even a majority of the factors, is controlling;
rather, the facts and circumstances of the case remain the
primary test. Keanini v. Commissioner, supra at 47.
Respondent argues that the Johnstons were not engaged in
their farm activity with an intent to make a profit. To support
this contention respondent relies on Bessenyey v. Commissioner,
45 T.C. 261, 274 (1965), affd. 379 F.2d 252 (2d Cir. 1967), and
section 1.183-2(b)(6), Income Tax Regs. for the proposition that
losses which continue to occur beyond the formative years, if not
explained, may indicate that an activity is not engaged in for
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