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of section 162(a) generally depends upon whether the taxpayer's
purpose for engaging in the activity is for income or profit, and
whether the activity is conducted with continuity and regularity.
Commissioner v. Groetzinger, 480 U.S. 23, 35 (1987). Section
183(a) disallows any deductions attributable to "activities not
engaged in for profit" except as provided in section 183(b).
Respondent argues that petitioners' research activity was
not engaged in for profit and any claimed deductions are subject
to the limitations of section 183(b). Furthermore, respondent
contends that petitioners must substantiate any deductions
claimed. Rule 142(a).
Whether a taxpayer engaged in an activity with the primary
purpose of making a profit is a question of fact. Dreicer v.
Commissioner, 78 T.C. 642, 644-645 (1982), affd. without
published opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-
2(a), Income Tax Regs. While a reasonable expectation of profit
is not required, taxpayer's profit objective must be bona fide.
Taube v. Commissioner, 88 T.C. 464, 478-479 (1987). In making
this determination, the Court gives more weight to objective
facts than to a taxpayer's mere statement of intent. Dreicer v.
Commissioner, supra at 645; sec. 1.183-2(a), Income Tax Regs.
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. The factors
include: (1) The manner in which the taxpayer carried on the
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