- 7 -
Commissioner, 85 T.C. 557, 569 (1985)). While a reasonable
expectation of profit is not required, the taxpayer's profit
objective must be bona fide. See Hulter v. Commissioner, 91 T.C.
371 (1988). Whether a taxpayer had an actual and honest profit
objective is a question of fact to be resolved from all relevant
facts and circumstances. See id. at 393; Golanty v.
Commissioner, 72 T.C. 411, 426 (1979), affd. without published
opinion 647 F.2d 170 (9th Cir. 1981). The burden of proving such
objective is on petitioner. Rule 142(a); see Welch v. Helvering,
290 U.S. 111 (1933). In resolving this factual question, greater
weight is given to objective facts than to the taxpayer's after-
the-fact statements of intent. See Thomas v. Commissioner, 84
T.C. 1244, 1269 (1985), affd. 792 F.2d 1256 (4th Cir. 1986);
Siegel v. Commissioner, 78 T.C. 659, 699 (1982); sec. 1.183-2(a),
Income Tax Regs.
Section 1.183-2(b), Income Tax Regs., sets forth a
nonexclusive list of nine objective factors relevant to the
determination of whether an activity is engaged in for profit.
These factors are: (1) The manner in which the taxpayer carries
on the activity; (2) the expertise of the taxpayer or his
advisers; (3) the time and effort expended 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
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