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T.C. 642, 645 (1982), affd. without published opinion 702 F.2d
1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs. In
making this determination, more weight is accorded to objective
facts than to the taxpayer's statement of intent. Engdahl v.
Commissioner, 72 T.C. 659, 666 (1979); sec. 1.183-2(a), Income
Tax Regs. Petitioners bear the burden of proving that they
possessed the required profit objective. Rule 142(a); Dreicer v.
Commissioner, supra; Golanty v. Commissioner, 72 T.C. 411, 426
(1979), affd. without published opinion 647 F.2d 170 (9th Cir.
1981).
In determining whether an activity is engaged in for profit,
reference is made to objective standards, taking into account all
of the facts and circumstances of each case. Sec. 1.183-2(a),
Income Tax Regs. The regulations set forth nine criteria
normally considered for this purpose. The 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 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
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