Wilbur Kenneth Griesmer - Page 8

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          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) any elements indicating personal pleasure or recreation.             
          See sec. 1.183-2(b), Income Tax Regs.                                        
               In the present case, none of the factors indicates that                 
          petitioner carried on his meteorite and pyrite collection                    
          activity with the requisite profit objective.  The ultimate goal             
          of an activity engaged in for profit must be to realize a net                
          profit from the activity so as to recoup losses sustained in                 
          prior years.  See Bessenyey v. Commissioner, 45 T.C. 261, 274                
          (1965), affd. 379 F.2d 252 (2d Cir. 1967).  In this regard,                  
          petitioner did not have a single dollar of gross receipts from               
          this activity, nor did he even offer any part of his collection              
          for sale.  See sec. 1.183-2(b)(6) and (7), Income Tax Regs.  This            
          factor indicates the lack of a profit objective.                             
               Further, petitioner did not carry on his meteorite and                  
          pyrite collection activity in a businesslike manner.  He did not             
          maintain any books or records of his income and expenses.  See               
          sec. 1.183-2(b)(1), Income Tax Regs.  Petitioner also does not               
          have any special skill or expertise with regard to meteorites or             

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