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Fuchs v. Commissioner, 83 T.C. 79, 97-98 (1984); 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.
Although a reasonable expectation of profit is not required, the
taxpayer's profit objective must be bona fide. See Hulter v.
Commissioner, 91 T.C. 371, 393 (1988); Beck v. Commissioner, 85
T.C. 557, 569 (1985). Whether a taxpayer had an actual and
honest profit objective is a question of fact to be resolved from
all relevant facts and circumstances. See Carter v.
Commissioner, 645 F.2d 784, 786 (9th Cir. 1981), affg. T.C. Memo.
1978-202; Hulter v. Commissioner, supra at 393; Golanty v.
Commissioner, 72 T.C. 411, 426 (1979), affd. without published
opinion 647 F.2d 170 (9th Cir. 1981). Greater weight is given to
objective facts than to a taxpayer's statement of intent. See
Beck v. Commissioner, supra at 570; Thomas v. Commissioner, 84
T.C. 1244, 1269 (1985), affd. 792 F.2d 1256 (4th Cir. 1986); sec.
1.183-2(a), Income Tax Regs.
Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of factors that should be considered in
determining whether an activity is engaged in with the requisite
profit objective. The nine factors are: (1) The manner in which
the taxpayer carries on the activity; (2) the expertise of the
taxpayer or his or her advisers; (3) the time and effort expended
by the taxpayer in carrying on the activity; (4) the expectation
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