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the factors that support each party's position. See sec. 1.183-
2(b), Income Tax Regs. Moreover, certain factors are given more
weight than others because they are more meaningfully applied to
the facts in this case. Respondent concedes that the fourth
element, the expectation that assets used in the activity may
appreciate in value, is inapplicable to the present case.
Taking into account the above factors and considering the
record as a whole, we conclude that, during the years in issue,
petitioner had a bona fide intention to derive a profit from his
writing activity. In addition to petitioner's testimony, which
we found to be credible and forthright, the evidence in the
record shows an intent and effort by petitioner to engage in and
continue in the writing field with the purpose of producing
income and a livelihood.
We first look to the manner in which petitioner carried on
the activity. Petitioner managed some aspects of this activity
in a businesslike fashion. He kept bills, receipts, and sched-
ules for his traveling expenses, and he kept a contemporaneous
journal to substantiate cash expenditures that he incurred to
interview prostitutes at the brothels, for which receipts were
not available. Petitioner was able to use his records, including
credit card statements, to compile logs for 1993 and 1994,
showing his travel dates, the dates, times, and places of his
interviews, the names of the prostitutes he interviewed, the per
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