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Commissioner, supra at 1552; Dreicer v. Commissioner, supra at
646; Golanty v. Commissioner, 72 T.C. 411, 426 (1979), affd.
without published opinion 647 F.2d 170 (9th Cir. 1981).
Section 1.183-2(b), Income Tax Regs., sets forth a
nonexclusive list of factors to be considered in determining
whether an activity is engaged in for profit. See Campbell v.
Commissioner, supra at 836. These factors are: (1) The manner in
which the taxpayer carried 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
loss 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) whether elements of personal pleasure or
recreation are involved. No single factor is controlling.
Rather, the facts and circumstances of the case taken as whole
are determinative. See Abramson v. Commissioner, 86 T.C. 360,
371 (1986); sec. 1.183-2(b), Income Tax Regs.
Petitioners’ proof with respect to their profit motive
consists in large part of Dr. Hillman’s uncorroborated self-
serving testimony. Because Dr. Hillman signed an income tax
return, under penalties of perjury, which reported that a donated
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