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No single factor is determinative, and all facts and
circumstances, including factors not listed, should be
considered. Abramson v. Commissioner, 86 T.C. 360, 371 (1986);
sec. 1.183-2(b), Income Tax Regs. Moreover, we do not resolve
the issue of profit objective by simply comparing the number of
factors indicating profit objective with those indicating the
lack of such an objective. Sec. 1.183-2(b), Income Tax Regs.
If gross income derived from a horse training or breeding
activity for 2 or more taxable years in a period of 7 consecutive
taxable years exceeds the deductions attributable to such
activity, then the activity is presumed to be an activity engaged
in for profit. Sec. 183(d). In the instant case, as gross
income from the activity did not exceed deductions from the
activity during any of the years in issue, petitioners are not
entitled to the presumption that Mr. Abbene's horse-related
activities were engaged in for profit. Consequently, we address
the aforementioned factors to decide whether Mr. Abbene engaged
in his horse-related activities through the operation of Blue
Ribbon with an actual and honest profit objective during the
years in issue.
1. Manner in Which the Taxpayer Carried On the Activity
The fact that the taxpayer carries on the activity in a
businesslike manner and maintains complete books and records may
indicate that the activity was engaged in for profit. Sec.
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