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(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)
elements of personal pleasure or recreation. Sec. 1.183-2(b),
Income Tax Regs.
No one factor is determinative in and of itself, and our
conclusion with respect to petitioner's profit motive does not
depend upon merely counting up those factors that suggest the
presence of a profit motive and comparing the number to those
factors that indicate the opposite. Sec. 1.183-2(b), Income Tax
Regs.
Taking into account the above factors and considering the
facts and circumstances relating to petitioner's dog breeding
activity, as discussed more fully below, we are not persuaded
that during 1993 petitioner engaged in that activity with the
intent to profit that is necessary to consider the activity a
trade or business for purposes of section 162. The activity did
generate gross income; however, not all income producing
activities constitute trades or businesses within the meaning of
section 162(a). Cf. Commissioner v. Groetzinger, supra at 35.
For the year in issue, the great majority of expense
deductions attributable to petitioner's dog breeding activity
were related to the Fleetwood motor home and Bronco that
petitioner owned. Deductions for the fixed costs of the those
vehicles, including depreciation, interest and insurance, totaled
$14,020. Deductions for the marginal costs attributable to those
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