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(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 appreci-
ate in value, (5) the success of the taxpayer in carrying on
other similar or dissimilar activities, (6) the taxpayer's
history of income or loss 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) the extent to which
elements of personal pleasure or recreation are involved. Sec.
1.183-2(b), Income Tax Regs. The list of factors in the regula-
tions is not exclusive, and other factors may be considered in
determining whether an activity is engaged in for profit. No
single factor is dispositive. E.g., Golanty v. Commissioner,
supra at 426; sec. 1.183-2(b), Income Tax Regs. The determina-
tion of a profit objective does not depend on counting the number
of factors that support each party's position. E.g., Dunn v.
Commissioner, supra at 720; sec. 1.183-2(b), Income Tax Regs.
Petitioners contend that during 1992 and 1993 they were
engaged in the roping horse activity for profit within the
meaning of section 183. Respondent disagrees. On the record
before us, we sustain respondent's position.
Mr. Haun has owned horses and competed with them since he
was a child. Since then, he has enjoyed using horses for, inter
alia, roping, trail riding, and hog hunting and has participated
in various recreational activities involving roping horses,
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