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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 primarily for 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 deeply interested in the activity, his motivation
appears to have been primarily his love for horses. Petitioner
had no formal or informal business plan and did not show that he
sought the advice of experts on how to conduct the activity on a
profitable basis. He failed to present evidence to show that he
spent a significant amount of time on the activity as he was
employed on a full time basis during 1996. There is no
indication in the record that petitioner undertook this activity
for any purposes other than his love for horses. Petitioner has
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