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to petitioner's automobile repair activity, petitioners contend
that there was a "profit trend" with respect to that activity.
Although not altogether clear, it appears that petitioners base
that contention on the premise that the amount of the losses that
petitioners claimed for 1992, 1993, 1994, and 1995 decreased from
year to year. We note initially that the respective losses that
petitioners claimed for 1994 and 1995 represented petitioner's
allocable share of certain partnership losses, which presumably
were less than the total losses for that partnership. More
importantly, we reject petitioners' contention that the losses
which they claimed for the years 1992, 1993, 1994, and 1995
establish a "profit trend" for petitioner's automobile repair
activity.
Based on our review of the entire record before us, we find
that petitioners have failed to demonstrate that petitioner was
engaged in his automobile repair activity with an actual and
honest objective of making a profit. The objective facts estab-
lished by that record indicate that most of the factors enumer-
ated in the regulations under section 183 favor respondent. We
further find based on the present record that petitioners have
failed to prove that the expenses that they claimed in their 1993
Schedule C and their 1993 amended Schedule C (1) were paid or
incurred during 1993 and/or (2) were ordinary and necessary to
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