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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 taxpayer’s financial status; and
(9) whether elements of personal pleasure or recreation are
involved. See sec. 1.183-2(b), Income Tax Regs.; see also Cannon
v. Commissioner, supra at 348-349.
The taxpayer's expectation of profit need not be reasonable
but must be in good faith. See Golanty v. Commissioner, 72 T.C.
411, 425-426 (1979), affd. without published opinion 647 F.2d 170
(9th Cir. 1981); Allen v. Commissioner, supra at 33; sec.
1.183-2(a), Income Tax Regs. In determining whether an activity
is engaged in for profit, greater weight is given to objective
factors than to a taxpayer's mere statement of intent. See
Anderson v. Commissioner, 62 F.3d 1266, 1274 n.16 (10th Cir.
1995), affg. T.C. Memo. 1993-607; Cannon v. Commissioner, supra
at 351 n.8; sec. 1.183-2(a), Income Tax Regs.
Although no one factor is conclusive, see sec. 1.183-2(b),
Income Tax Regs., a record of substantial losses over many years
and the unlikelihood of achieving a profit are indicative that an
activity is not engaged in for profit, see Hildebrand v.
Commissioner, supra at 1027; Cannon v. Commissioner, supra at
352; Golanty v. Commissioner, supra at 426; sec. 1.183-2(b)(6),
Income Tax Regs.
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