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allowable for the taxable year under section 162 or under
paragraph (1) or (2) of section 212."
For a deduction to be allowed under sections 162 or 212(1)
or (2), a taxpayer must establish that he or she engaged in the
activity with an actual and honest objective of making an
economic profit independent of tax savings. See Antonides v.
Commissioner, 91 T.C. 686, 693-694 (1988), affd. 893 F.2d 656
(4th Cir. 1990); Dreicer v. Commissioner, 78 T.C. 642, 644-645
(1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983).
The expectation of profit need not have been reasonable; however,
the taxpayer must have entered into the activity, or continued
it, with the objective of making a profit. See Hulter v.
Commissioner, 91 T.C. 371, 393 (1988); sec. 1.183-2(a), Income
Tax Regs.
Whether the requisite profit objective exists is determined
by looking to all the surrounding facts and circumstances. See
Keanini v. Commissioner, 94 T.C. 41, 46 (1990); sec. 1.183-2(b),
Income Tax Regs. Greater weight is given to objective facts than
to a taxpayer's mere after-the-fact statement of intent. See
Thomas v. Commissioner, 84 T.C. 1244, 1269 (1985), affd. 792 F.2d
1256 (4th Cir. 1986); sec. 1.183-2(a), Income Tax Regs.
Petitioners bear the burden of proof. See Rule 142(a).
Section 1.183-2(b), Income Tax Regs., provides a list of
factors to be considered in the evaluation of a taxpayer's profit
objective: (1) The manner in which the taxpayer carries on the
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