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Although a reasonable expectation of profit on taxpayer's part is
not required, the profit objective must be bona fide, as
determined from a consideration of the surrounding facts and
circumstances. Keanini v. Commissioner, supra at 46; Dreicer v.
Commissioner, supra at 645; Golanty v. Commissioner, 72 T.C.
411, 426 (1979), affd. without published opinion 647 F.2d 170
(9th Cir. 1981); Bessenyey v. Commissioner, 45 T.C. 261, 274
(1965), affd. 379 F.2d 252 (2d Cir. 1967).
Whether petitioner engaged in her writing activity with an
actual and honest objective of realizing a profit must be
redetermined year-to-year, taking into account all of the
relevant facts and circumstances. 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 petitioner's statement of her
intent. Engdahl v. Commissioner, 72 T.C. 659, 666 (1979); sec.
1.183-2(a), Income Tax Regs.
The following factors, which are nonexclusive, should be
considered in the determination of whether an activity is engaged
in for profit: (1) The manner in which the taxpayer carried on
the activity; (2) the expertise of the taxpayer or his or her
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 appreciate in value; (5) the success of the
taxpayer in carrying on other similar or dissimilar activities;
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