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actual and honest objective of making a profit. See Keanini v.
Commissioner, 94 T.C. 41, 46 (1990); Dreicer v. Commissioner, 78
T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205 (D.C.
Cir. 1983); sec. 1.183-2(a), Income Tax Regs. In making this
determination, more weight is accorded 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 regulations under section 183 provide nine nonexclusive
factors to be used in determining whether a taxpayer is engaged
in an activity with the objective to make a profit. See sec.
1.183-2(b), Income Tax Regs. The factors are: (1) The manner in
which the taxpayer carried on the activity; (2) the expertise of
the taxpayer or his advisers; (3) the time and effort expended by
the taxpayer in carrying on the activity; (4) the expectation
that the 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
loss 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 id. No single factor is controlling. Rather,
the facts and circumstances of the case taken as a whole are
determinative. See Abramson v. Commissioner, 86 T.C. 360, 371
(1986); sec. 1.183-2(b), Income Tax Regs.
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