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activity not engaged in for profit as an activity other than one
with respect to which deductions are allowable under section 162
or under paragraphs (1) or (2) of section 212. An activity
engaged in for profit is one in which the taxpayer has an actual
and honest objective of making a profit, Dreicer v. Commissioner,
78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205
(D.C. Cir. 1983), although that profit expectation need not be
reasonable, Taube v. Commissioner, 88 T.C. 464, 478-479 (1987);
sec. 1.183-2(a), Income Tax Regs.
The determination of a taxpayer's profit objective requires
a consideration of all the surrounding facts and circumstances.
Finoli v. Commissioner, 86 T.C. 697, 722 (1986); sec. 1.183-2(b),
Income Tax Regs. Although the purpose of the inquiry is to
ascertain the taxpayer's subjective intent, greater weight is
given to objective facts than to self-serving statements of
intent. Beck v. Commissioner, 85 T.C. 557, 570 (1985); sec.
1.183-2(a), Income Tax Regs.
In conducting the profit objective analysis, courts have
relied on a nonexclusive list of nine factors enumerated in the
regulations under section 183. See Independent Elec. Supply,
Inc. v. Commissioner, 781 F.2d 724, 727 (9th Cir. 1986), affg.
Lahr v. Commissioner, T.C. Memo. 1984-472; Elliott v. Commis-
sioner, 90 T.C. 960, 970-971 (1988), affd. without published
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