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objective facts than to their subjective statements, Holbrook v.
Commissioner, T.C. Memo. 1993-383; sec. 1.183-2(a), Income Tax
Regs.
The following factors, which are nonexclusive, aid in
determining whether an activity is engaged in for profit: (1)
The manner in which the taxpayer carries on the activity; (2) the
expertise of the taxpayer or his 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; (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 single factor is dispositive, Golanty v. Commissioner,
supra at 426; sec. 1.183-2(b), Income Tax Regs., and a profit
objective does not hinge on the number of factors satisfied, sec.
1.183-2(b), Income Tax Regs. We proceed to analyze these
factors.
1. Manner in Which Petitioners Carried On Their Activity
One indicator of an activity engaged in for profit is a
taxpayer's businesslike conduct of the activity. Sec.
1.183-2(b)(1), Income Tax Regs. This includes the keeping of
complete and accurate books and records. Id.
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