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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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