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objective exists. Some of these factors include: (1) The manner
in which the taxpayer carries on the activity; (2) the expertise
of the taxpayer or the taxpayer's advisers; (3) the time and
effort expended by the taxpayer in carrying on the activity; (4)
the expectation that the assets used in the activity may
appreciate in value. Sec. 1.183-2(b), Income Tax Regs.
No single factor, nor even the existence of a majority of
factors, favoring or disfavoring the existence of a profit
objective is controlling. Id. Rather, the relevant facts and
circumstances of the case are determinative. Golanty v.
Commissioner, 72 T.C. 411, 426 (1979), affd. without published
opinion 647 F.2d 170 (9th Cir. 1981).
Furthermore, the existence of the requisite profit objective
is a question of fact that must be determined on the basis of the
entire record. Benz v. Commissioner, 63 T.C. 375, 382 (1974).
In resolving this factual question, greater weight is accorded to
objective facts than a taxpayer's mere statement of intent. Beck
v. Commissioner, 85 T.C. 557, 570 (1985); Engdahl v.
Commissioner, 72 T.C. 659, 667 (1979); Churchman v. Commissioner,
68 T.C. 696, 701 (1977); see sec. 1.183-2(a), Income Tax Regs.
To be entitled to a loss under section 165(c)(2),
petitioners' "primary" motive for entering into the transaction
must have been to make a profit. Fox v. Commissioner, 82 T.C.
1001, 1021 (1984). The term "primary" is defined as "of first
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