- 13 - Section 1.183-2(b), Income Tax Regs., provides a list of factors to be considered in the evaluation of a taxpayer’s profit objective: (1) The manner in which the taxpayer carries on the activity; (2) the expertise of the taxpayer or his advisors; (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, from the activity; (8) the financial status of the taxpayer; and (9) elements of personal pleasure or recreation. This list is nonexclusive, the number of factors for or against the taxpayer is not necessarily determinative, 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); sec. 1.183- 2(b), Income Tax Regs. Petitioners contend that because the activities were profit motivated they properly reported losses from the ranching and farming activities. Conversely, respondent asserts that the activities were not engaged in for profit. We agree with respondent.6 6 On Schedule F of their tax returns, petitioners reported the ranching and farming activities on the four properties as one activity. In their briefs, petitioners seem to argue that the ranching and farming activities on the four properties are one activity. Respondent argues that we should treat each propertyPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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