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other issues T.C. Memo. 1993-519; Surloff v. Commissioner, 81
T.C. 210, 233 (1983); Dreicer v. Commissioner, 78 T.C. 642, 645
(1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983). In
deciding whether petitioners operated their horse-breeding
activity for profit, we apply the following nine nonexclusive
factors: (1) The manner in which the taxpayer carried on the
activity; (2) the expertise of the taxpayer or his or her
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, if
any, which are earned; (8) the financial status of the taxpayer;
and (9) whether elements of personal pleasure or recreation are
involved. See sec. 1.183-2(b), Income Tax Regs. No single
factor controls. See Osteen v. Commissioner, supra; Brannen v.
Commissioner, 722 F.2d 695, 704 (11th Cir. 1984), affg. 78 T.C.
471 (1982); sec. 1.183-2(b), Income Tax Regs. Petitioners have
the burden of proof. See Golanty v. Commissioner, 72 T.C. 411,
426 (1979), affd. without published opinion 647 F.2d 170 (9th
Cir. 1981).
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