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(6) the taxpayer's history of income or losses 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)
elements of personal pleasure or recreation. Sec. 1.183-2(b),
Income Tax Regs.
No one factor is determinative in and of itself, and our
conclusion with respect to petitioner's profit motive does not
depend upon merely counting up those factors that suggest the
presence of a profit motive and comparing the number to those
factors that indicate the opposite. Sec. 1.183-2(b), Income Tax
Regs.
Taking into account the above factors and considering the
facts and circumstances relating to petitioner's writing
activity, as discussed more fully below, we are not persuaded
that during the years in issue petitioner engaged in that
activity with the intent to profit that is necessary to consider
the writing activity a trade or business for purposes of section
162. The activity did generate income; however, not all income
producing activities constitute trades or businesses within the
meaning of section 162(a). Cf. Commissioner v. Groetzinger,
supra at 35.
In each year in issue, the great majority of expense
deductions attributable to petitioner's writing activity were
related to travel. We are particularly influenced by
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