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account, and more weight may be given to some factors than to
others. Glenn v. Commissioner, T.C. Memo. 1995-399, affd.
without published opinion 103 F.3d 129 (6th Cir. 1996); Sec.
1.183-2(b), Income Tax Regs. None of these factors is
dispositive. Golanty v. Commissioner, 72 T.C. 411, 426 (1979),
affd. without published opinion 647 F.2d 170 (9th Cir. 1981).
Dr. DeMattia testified that he had an honest objective of
making a profit from the golf sponsorship agreements with his
son. He further testified that he believed that he would make
millions of dollars as a result of the sponsorship agreements.
We give greater weight to objective factors than to Dr.
DeMattia's uncorroborated testimony as to his intent in
determining whether he had the requisite profit objective.
Keanini v. Commissioner, 94 T.C. 41, 46 (1990); Dreicer v.
Commissioner, supra at 645; sec. 1.183-2(a), Income Tax Regs.
1. Manner in Which the Activity is Conducted
That the taxpayer carried on the activity in a businesslike
manner and maintained complete and accurate records may indicate
that the activity is engaged in for profit. Sec. 1.183-2(b)(1),
Income Tax Regs. Additionally, a change in operating procedures,
adoption of new techniques, or the abandonment of unprofitable
methods indicates a profit motive. Id.
Among other things, respondent argues that the following
facts establish that Dr. DeMattia failed to conduct the activity
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