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F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs.
The taxpayer's motive to make a profit must be analyzed by
looking at all the surrounding objective facts. Dreicer v.
Commissioner, supra at 645. These facts are given greater weight
than to petitioners' mere statement of intent. Dreicer v.
Commissioner, supra.
Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of relevant factors to be considered in
deciding whether an activity is engaged in for profit. These
factors are: (1) The manner in which the taxpayer carries on the
activity; (2) the expertise of the taxpayer or his advisors; (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 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) elements of personal
pleasure or recreation. Sec. 1.183-2(b), Income Tax Regs. These
factors are not applicable or appropriate in every case.
Abramson v. Commissioner, 86 T.C. 360, 371 (1986).
After a review of the record, we conclude that respondent
has carried the burden of proving that petitioners lacked the
requisite profit objective within the meaning of section 183 in
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