Barry S. and Yvonne C. Hillman - Page 14

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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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