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allowable for the taxable year under section 162 or under
paragraph (1) or (2) of section 212. Sec. 183(c).
The taxpayer must show that he engaged in the activity with
the actual and honest objective of making a profit. Dreicer v.
Commissioner, 78 T.C. 642, 645 (1982), affd. without opinion 702
F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs.
The taxpayer's expectation of a profit need not be reasonable,
but it must be a bona fide expectation. Sec. 1.183-2(a), Income
Tax Regs. Whether a taxpayer is engaged in an activity with the
requisite profit objective is determined from all the facts and
circumstances. Dreicer v. Commissioner, supra at 645. Greater
weight is given to objective facts than to the taxpayer's mere
statement of his intent. Dreicer v. Commissioner, supra at 645;
sec. 1.183-2(a), Income Tax Regs.
Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of relevant factors to be considered in
deciding whether an activity is engaged in for profit. These
factors are: (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) expectation that 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 losses with respect to the activity; (7) the amount
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