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the expectation that the assets used in the activity may
appreciate in value, (5) the success of the taxpayer in carrying
on similar or dissimilar activities, (6) the taxpayer's history
of income or loss 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) the extent to which elements of
personal pleasure are involved. Sec. 1.183-2(b), Income Tax
Regs. The list of factors in the regulations is not exclusive,
and other factors may be considered in determining whether an
activity is engaged in for profit. No single factor is
determinative. Golanty v. Commissioner, supra at 426; sec.
1.183-2(b), Income Tax Regs. The determination of a profit
objective does not depend on counting the number of factors that
support each party's position. Dunn v. Commissioner, supra at
720; sec. 1.183-2(b), Income Tax Regs.
A review of the entire record in this case persuades us that
petitioners have failed to carry their burden of proving that
their apple orchard activity was engaged in for profit. We find
that all of the above enumerated factors weigh against
petitioners.
First, the manner in which the taxpayer carries on the
activity is one indication of whether a profit objective exists.
Sec. 1.183-2(b)(1), Income Tax Regs. Elements relevant to this
factor include whether the taxpayer maintained complete and
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