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indicate that the taxpayer entered into the activity, or
continued it, with the actual and honest objective of making a
profit. Id.; Dreicer v. Commissioner, supra at 645; sec. 1.183-
2(a), Income Tax Regs.
Whether a taxpayer has an actual and honest profit objective
is decided on the basis of all surrounding circumstances.
Dreicer v. Commissioner, supra at 645; sec. 1.183-2(b), Income
Tax Regs. In making our determination, we give greater weight to
objective factors than to a taxpayer's statement of intent.
Dreicer v. Commissioner, supra at 645; sec. 1.183-2(a), Income
Tax Regs.
Partnership activities present special considerations in
determining whether they are entered into for profit.
"Partnerships are mere formal entities. Obviously, they do not
have independent minds of their own." Fox v. Commissioner, 80
T.C. 972, 1007 (1983), affd. without published opinion 742 F.2d
1441 (2d Cir. 1984), affd. sub nom. Barnard v. Commissioner, 731
F.2d 230 (4th Cir. 1984), affd. without published opinions sub
nom. Hook v. Commissioner, Kratsa v. Commissioner, Leffel v.
Commissioner, Rosenblatt v. Commissioner, Zemel v. Commissioner,
734 F.2d 5-9 (3d Cir. 1984). In determining partnership intent,
we often focus on the actions taken by the general partner.
Finoli v. Commissioner, 86 T.C. 697, 722 (1986).
Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of objective factors to be considered in
deciding whether an activity is engaged in for profit. Allen v.
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