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opinion 702 F.2d 1205 (D.C. Cir. 1983); Golanty v. Commissioner,
72 T.C. 411, 426 (1979), affd. without published opinion 647 F.2d
170 (9th Cir. 1981). Although the taxpayer's expectation of a
profit need not be reasonable, he or she must have a good faith
objective of making a profit. Dreicer v. Commissioner, supra at
645; Dunn v. Commissioner, 70 T.C. 715, 720 (1978), affd. on
another issue 615 F.2d 578 (2d Cir. 1980); sec. 1.183-2(a),
Income Tax Regs. Petitioners bear the burden of proving the
requisite intent. Golanty v. Commissioner, supra at 426.
Whether a taxpayer is engaged in an activity with the requisite
profit objective is determined from all the facts and
circumstances. Hulter v. Commissioner, 91 T.C. 371, 393 (1988);
Golanty v. Commissioner, supra at 426; sec. 1.183-2(a) and (b),
Income Tax Regs. Petitioners assert that they engaged in the
apple orchard activity with the objective of making a profit;
however, more weight is given to objective facts than to the
taxpayers' mere statement of their intent. Dreicer v.
Commissioner, supra at 645; sec. 1.183-2(a), Income Tax Regs.
The regulations promulgated under section 183 list the
following nine factors that should normally be taken into account
in determining whether an activity is engaged in for profit: (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)
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