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Petitioners contend that Red Caboose was an activity in
which they engaged with the objective of making a profit during
the years in issue. Respondent, on the other hand, contends that
petitioners' operation of Red Caboose was an activity "not
engaged in for profit" within the meaning of section 183(c).
Whether the required profit objective exists is to be
determined on the basis of all the facts and circumstances of
each case. Allen v. Commissioner, 72 T.C. 28, 33 (1979).
Section 1.183-2(b), Income Tax Regs., sets forth some of the
relevant factors to be considered in deciding whether an activity
is engaged in for profit. No one factor is controlling. Dunn v.
Commissioner, 70 T.C. 715, 720 (1978), affd. 615 F.2d 578 (2d
Cir. 1980). The factors include: (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) 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 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) whether elements of personal pleasure or
recreation are involved. Sec. 1.183-2(b), Income Tax Regs.
While the focus of the test is on the subjective intention of the
taxpayer, greater weight is given to the objective facts than to
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