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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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