Joyce E. Hastings - Page 13




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          (1979), affd. without published opinion 647 F.2d 170 (9th Cir.               
          1981).                                                                       
               In determining whether an activity is engaged in for profit,            
          reference is made to objective standards, taking into account all            
          of the facts and circumstances of each case.  See sec. 1.183-                
          2(a), Income Tax Regs.  The regulations set forth nine criteria              
          normally considered for this purpose.  The 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) the expectation that 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, that are earned; (8) the               
          financial status of the taxpayer; and (9) the presence of                    
          elements of personal pleasure or recreation.  See sec. 1.183-                
          2(b), Income Tax Regs.  None of these factors is determinative,              
          nor is the decision to be made by comparing the number of factors            
          that weigh in the taxpayer’s favor with the number that support              
          the Commissioner.  See id.                                                   
               Petitioner contends that she had the requisite profit                   
          objective with respect to her horse-breeding and showing                     
          activity.  Conversely, respondent contends that the activity was             





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