Anthony W. Jorgenson and Florence A. Jorgenson - Page 13




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               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 property             



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