-17-
opinion 702 F.2d 1205 (D.C. Cir. 1983). Although the taxpayer's
expectation of profit need not be reasonable, it must be bona
fide, as determined from all the surrounding facts and circum-
stances. See Keanini v. Commissioner, 94 T.C. 41, 46 (1990);
Dreicer v. Commissioner, supra at 645. Thus, whether the
requisite profit motive exists is a factual question that must be
determined upon the record, see Benz v. Commissioner, 63 T.C.
375, 382 (1974), with more weight given to objective facts than
to petitioner's statement of intent. See Engdahl v. Commis-
sioner, 72 T.C. 659, 666 (1979); sec. 1.183-2(a), Income Tax
Regs.
The Treasury regulations list nine factors as an aid in
making the profit objective determination. They include:
(1) The manner in which the taxpayer carried on the activity;
(2) the expertise of the taxpayer or his 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 loss with respect to the activity; (7) the
amount of occasional profits that are earned; (8) the financial
status of the taxpayer; and (9) whether elements of personal
pleasure or recreation are involved. No one factor is conclu-
sive, and we do not reach our decision herein by merely counting
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