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Whether the required profit objective exists is to be
determined on the basis of all the facts and circumstances of
each case. See Hirsch v. Commissioner, 315 F.2d 731, 737 (9th
Cir. 1963), affg. T.C. Memo. 1961-256; Golanty v. Commissioner,
72 T.C. 411, 426 (1979), affd. without published opinion 647 F.2d
170 (9th Cir. 1981); sec. 1.183-2(a), Income Tax Regs. While a
reasonable expectation of profit is not required, the taxpayer's
objective of making a profit must be bona fide. See Elliott v.
Commissioner, 84 T.C. 227, 236 (1985), affd. without published
opinion 782 F.2d 1027 (3d Cir. 1986). In making this factual
determination, we give greater weight to objective factors than
to a taxpayer's mere statement of his or her intent. See
Independent Elec. Supply, Inc. v. Commissioner, 781 F.2d 724, 726
(9th Cir. 1986), affg. Lahr v. Commissioner, T.C. Memo. 1984-472;
Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without
opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income
Tax Regs.
Section 1.183-2(b), Income Tax Regs., sets forth nine
factors we consider to determine whether taxpayers engaged in a
venture with a profit objective. They include: (1) The manner
in which the taxpayers carried on the activity; (2) the expertise
of the taxpayers or their advisers; (3) the time and effort
expended by the taxpayers in carrying on the activity; (4) the
expectation that the assets used in the activity may appreciate
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