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The issue is one of fact and is to be resolved not on the
basis of any one factor, but on the basis of all of the facts
and surrounding circumstances. Allen v. Commissioner, 72 T.C.
28, 34 (1979); sec. 1.183-2(b), Income Tax Regs. Petitioners
bear the burden of proving that their timber farm and their
Tahiti Property, during the years in issue, constituted the
actual, good faith conduct of a trade or business or of an
activity entered into for profit. Rule 142(a).
Section 1.183-2(b), Income Tax Regs., provides a list of
nine nonexclusive factors that are to be analyzed in determining
whether an activity was conducted with an actual and honest
objective of making a profit, as follows: (1) The manner in
which the taxpayer carried on the activity; (2) the taxpayer's
expertise; (3) the time and effort expended by the taxpayer in
carrying on the activity; (4) the expectation that the assets
used in the activity would appreciate in value; (5) the success
of the taxpayer in carrying on the activity; (6) the taxpayer's
history of income or losses with respect to the activity;
(7) the amount of profits, if any, which are realized in the
activity; (8) the financial status of the taxpayer; and
(9) whether elements of personal pleasure or recreation are
involved. More weight is to be given to objective factors than
to a taxpayer's mere statement of intent. Beck v. Commissioner,
85 T.C. 557, 570 (1985). Further, the absence of one particular
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