6
petitioner was engaged in tournament fishing for profit depends
on whether he was so engaged "with an ‘actual and honest’
objective of making a profit." Elliott v. Commissioner, 90 T.C.
960, 970 (1988), affd. without published opinion 899 F.2d 18 (9th
Cir. 1990); Dreicer v. Commissioner, 78 T.C. 642, 645 (1982),
affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983). Although a
reasonable expectation of profit is not required, petitioner's
profit objective must have been bona fide. Hulter v.
Commissioner, 91 T.C. 371, 393 (1988). Whether petitioner
possessed the necessary objective is a question of fact to be
determined based on all facts and circumstances, and petitioner
bears the burden of proving such objective. Taube v.
Commissioner, 88 T.C. 464, 480 (1987).
The regulations set forth the following nonexclusive factors
to consider in determining whether an activity is engaged in for
profit: (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 activities; (6) the taxpayer's history of
income or losses with respect to the activity; (7) the amount of
occasional profit, if any, which is earned; (8) the financial
status of the taxpayer; and (9) whether elements of personal
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