Otis W. Jordan and Alma F. Jordan - Page 7

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          v. Commissioner, supra at 645; Golanty v. Commissioner, 72 T.C.             
          411, 426 (1979), affd. without published opinion 647 F.2d 170               
          (9th Cir. 1981); Bessenyey v. Commissioner, 45 T.C. 261, 274                
          (1965), affd. 379 F.2d 252 (2d Cir. 1967).  Whether a taxpayer              
          engaged in an activity with an actual and honest objective of               
          realizing a profit must be determined year to year.  See Golanty            
          v. Commissioner, supra at 426; sec. 1.183-2(a) and (b), Income              
          Tax Regs.  More weight is given to objective facts than to the              
          taxpayer’s statement of intent.  See Engdahl v. Commissioner, 72            
          T.C. 659, 666 (1979); sec. 1.183-2(a), Income Tax Regs.                     
               The following factors, which are nonexclusive, are taken               
          into account in deciding whether an activity is engaged in for              
          profit:  (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 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 losses 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)               
          elements of personal pleasure or recreation.  See sec. 1.183-               
          2(b), Income Tax Regs.                                                      
               We have considered similar issues in numerous other cases              
          and, from time to time, include in our discussion a factor-by-              

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