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and circumstances. Hulter v. Commissioner, 91 T.C. 371, 393
(1988); Golanty v. Commissioner, supra at 426; sec. 1.183-2(a)
and (b), Income Tax Regs. The proper focus of the test is the
taxpayer's subjective intention, but objective indicia may be
used to determine the taxpayer's true intent. Independent
Electric Supply, Inc. v. Commissioner, supra at 726. In this
regard, more weight is generally given to objective facts than to
the taxpayer's mere statement of her intent. 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., provides a list of
factors to be considered in deciding whether an activity is
engaged in for profit. These factors include: (1) The manner in
which the taxpayer carried on the activity; (2) the expertise of
the taxpayer or her advisers; (3) the time and effort expended by
the taxpayer in carrying on the activity; (4) the expectation
that the 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, which are earned; (8) the financial status of
the taxpayer; and (9) whether elements of personal pleasure or
recreation are involved. Sec. 1.183-2(b), Income Tax Regs. This
list of factors is not exclusive, and other factors may be
considered in determining whether an activity is engaged in for
profit. The factors are not merely a counting device where the
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