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statement of intent. Independent Elec. Supply, Inc. v.
Commissioner, 781 F.2d 724 (9th Cir. 1986), affg. Lahr v.
Commissioner, T.C. Memo. 1984-472; Beck v. Commissioner, supra at
570; Thomas v. Commissioner, 84 T.C. 1244, 1269 (1985), affd. 792
F.2d 1256 (4th Cir. 1986); Dreicer v. Commissioner, supra.
Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of factors relevant to the issue as to whether
the taxpayer has the requisite profit objective. These factors
are: (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 the assets utilized by the
taxpayer 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. Not
all of these factors are applicable in every case. Brannen v.
Commissioner, 722 F.2d 695, 704 (11th Cir. 1984), affg. 78 T.C.
471 (1982); Taube v. Commissioner, 88 T.C. 464, 479-480 (1987);
Abramson v. Commissioner, 86 T.C. 360, 371 (1986); Allen v.
Commissioner, supra at 34. No one factor nor a majority of the
factors is necessarily determinative, and we do not reach our
conclusion by simply counting the factors that support each
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