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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) the
presence of elements of personal pleasure or recreation. Not all
of these factors are applicable in every case, and no one factor
is controlling. See sec. 1.183-2(b), Income Tax Regs. Although
these factors are helpful in ascertaining a taxpayer’s objective
in engaging in the activity, no single factor, nor the existence
of even a majority of the factors, is controlling. See Keanini
v. Commissioner, 94 T.C. 41, 46 (1990). We now apply these
factors to petitioner’s farming and harness-racing activities.
Farming Activities
Petitioner did not present any evidence regarding the manner
in which he operates his farm. He generally stated that he did
the plowing and the planting, and that while he did have some
help, he and his family did almost all of the labor in what he
described as an “extensive farming operation that didn’t turn out
to be very profitable.” He did not present any explicit evidence
regarding how much time he spent on his farming activities,
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