George F. Walker - Page 9

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               Section 1.183-2(b), Income Tax Regs., provides a nonexclu-             
          sive list of factors to be considered in determining whether an             
          activity is engaged in for profit.  The factors include:  (1) The           
          manner in which the taxpayer carried 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 the 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) whether elements of               
          personal pleasure or recreation are involved.                               
               On the basis of all of the evidence presented at trial, we             
          conclude that petitioner lacked the requisite profit motive in              
          carrying on his minority education business.  Petitioner                    
          described his business as minority education programs that local            
          municipalities and school districts would purchase and thereby              
          become eligible for grant money from the Department of Education.           
          However, the record lacks even basic information concerning                 
          petitioner's minority education programs.  It is unclear what               
          subject matter, or grade level, was being targeted by peti-                 
          tioner's programs.  Petitioner did not disclose what type of                
          academic materials were associated with his minority education              

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