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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 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. Sec.
1.183-2(b), Income Tax Regs. No single factor is determinative.
See Keanini v. Commissioner, supra at 47; Taube v. Commissioner,
88 T.C. 464, 479-480 (1987); sec. 1.183-2(b), Income Tax Regs.
Petitioner's objective is a question of fact to be determined
from all the facts and circumstances, keeping in mind that
petitioners bear the burden of proof. See Rule 142(a); Evans v.
Commissioner, 908 F.2d 369, 372-373 (8th Cir. 1990), revg. T.C.
Memo. 1988-468; sec. 1.183-2(a), Income Tax Regs.
D. Analysis
1. Nature of the Schedule F Activity
Petitioner became a part owner of a ranch (the Arkansas
ranch) in 1985. He and another individual used the Arkansas
ranch to raise cattle, horses, and crops, which they sold. In
1991, petitioner purchased the other individual’s interest in the
Arkansas ranch and ended his relationship with that individual
(with respect to the ranch). Petitioner began purchasing horses
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