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Hulter v. Commissioner, 91 T.C. 371, 392 (1988); Dreicer v.
Commissioner, 78 T.C. 642, 645 (1982), affd. without opinion 702
F.2d 1205 (D.C. Cir. 1983). Although the taxpayer's expectation
of a profit need not be reasonable, he or she must have a good
faith objective of making a profit. E.g., Dreicer v. Commis-
sioner, supra at 645; Dunn v. Commissioner, 70 T.C. 715, 720
(1978), affd. on another issue 615 F.2d 578 (2d Cir. 1980); sec.
1.183-2(a), Income Tax Regs. Petitioners bear the burden of
proving the requisite intent. E.g., Golanty v. Commissioner, 72
T.C. 411, 426 (1979), affd. without published opinion 647 F.2d
170 (9th Cir. 1981); Johnson v. Commissioner, 59 T.C. 791, 813
(1973), affd. 495 F.2d 1079 (6th Cir. 1974). Whether a taxpayer
is engaged in an activity with the requisite profit objective is
determined from all the facts and circumstances. E.g., Hulter v.
Commissioner, supra at 393; Taube v. Commissioner, 88 T.C. 464,
480 (1987); Golanty v. Commissioner, supra at 426; sec. 1.183-
2(a) and (b), Income tax Regs. More weight is given to objective
facts than to the taxpayer's mere statement of his or her intent.
E.g., Dreicer v. Commissioner, supra at 645; sec. 1.183-2(a),
Income Tax Regs.
The regulations promulgated under section 183 list the
following nine factors that should normally be taken into account
in determining whether an activity is engaged in for profit:
(1) The manner in which the taxpayer carried on the activity,
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