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primarily as a sport, hobby, or for recreation. Thus, an
activity carried on primarily for any such purpose is not an
activity engaged in for profit. See sec. 1.183-2(a), Income Tax
Regs.
C. Actual and Honest Profit Objective
An activity is engaged in for profit if the taxpayer has an
"actual and honest objective of making a profit." Keanini v.
Commissioner, 94 T.C. 41, 46 (1990) (quoting Dreicer v.
Commissioner, 78 T.C. 642, 644-645 (1982), affd. without opinion
702 F.2d 1205 (D.C. Cir. 1983)). Although the expectation of
profit need not be reasonable, a bona fide profit objective must
exist. See Keanini v. Commissioner, supra; Dreicer v.
Commissioner, supra; Golanty v. Commissioner, 72 T.C. 411,
425-426 (1979), affd. without published opinion 647 F.2d 170 (9th
Cir. 1981); sec. 1.183-2(a), Income Tax Regs. Profit in this
context means economic profit, independent of tax savings. See
Antonides v. Commissioner, 91 T.C. 686, 694 (1988), affd.
893 F.2d 656 (4th Cir. 1990); Hulter v. Commissioner, 91 T.C.
371, 393 (1988).
The regulations promulgated under section 183 provide the
following nonexclusive list of factors to be considered in
determining whether an activity is engaged in for profit:
(1) The manner in which the taxpayer carried on the activity,
(2) the expertise of the taxpayer or his or her advisers, (3) the
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