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history of income or losses with respect to the activity; (7) the
amount of occasional profits earned, if any; (8) the financial
status of the taxpayer; and (9) the elements of personal pleasure
or recreation involved. These factors are not merely a counting
device where the number of factors for or against the taxpayer is
determinative, but rather all facts and circumstances must be
taken into account, and more weight may be given to some factors
than to others. Cf. Dunn v. Commissioner, 70 T.C. 715, 720
(1978), affd. 615 F.2d 578 (2d Cir. 1980). Not all factors are
applicable in every case, and no one factor is controlling. See
Abramson v. Commissioner, 86 T.C. 360, 371 (1986); sec. 1.183-
2(b), Income Tax Regs. Further, the determination of a
taxpayer's profit motive is made on a yearly basis. See
Commissioner v. Sunnen, 333 U.S. 591, 598 (1948).
On this record, the Court is satisfied that petitioner's
activity was not carried on with an actual and honest objective
of making a profit. It is fair to conclude, among other things,
that the activity was not conducted in a businesslike manner.
Although the Court is satisfied that petitioner was dedicated to
the activity, her motivation was primarily her love for horses.
Despite years of substantial losses, petitioner had no formal or
informal business plan and never sought the advice of experts on
how to conduct the activity on a profitable basis. See Bessenyey
v. Commissioner, 45 T.C. 261, 274 (1965) ("the goal must be to
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