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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 that are earned;
(8) the financial status of the taxpayer; and (9) whether
elements of personal pleasure or recreation are involved. No
single factor is controlling, and we do not reach our decision by
merely counting the factors that support each party’s position.
Dunn v. Commissioner, 70 T.C. 715, 720 (1978), affd. 615 F.2d 578
(2d Cir. 1980); sec. 1.183-2(b), Income Tax Regs. Certain
elements are given more weight than others because they are more
meaningfully applied to the facts in our case.
Upon reviewing the record, we conclude that, during 1993,
petitioner did not engage in the writing activity with the
requisite profit objective. Petitioner did not carry on this
activity in a businesslike manner, as he did not maintain any
books and records. See sec. 1.183-2(b)(1), Income Tax Regs.
Moreover, since 1983, petitioner submitted only one manuscript
for publication and earned no income from his writing activity.
In addition, petitioner did not demonstrate that he changed his
operation to improve profitability, had a business plan, or
investigated the basic factors that affect profitability.
Lastly, petitioner had sufficient income from his INS,
Chapman, and Navy work to use the claimed tax benefits created
from his writing activity. See sec. 1.183-2(b)(8), Income Tax
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