Robert L. and Joanne Tammaro - Page 15




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               The existence of the requisite profit objective is a                   
          question of fact that must be determined on the basis of the                
          entire record.  See Benz v. Commissioner, 63 T.C. 375, 382                  
          (1974).  In resolving this factual question, greater weight is              
          accorded objective facts than a taxpayer's statement of intent.             
          See sec. 1.183-2(a), Income Tax Regs.  For purposes of                      
          determining whether a taxpayer had the requisite profit                     
          objective, profit means economic profit, independent of tax                 
          savings.  See Surloff v. Commissioner, 81 T.C. 210, 233 (1983).             
               The regulations set forth a nonexhaustive list of factors              
          that may be considered in deciding whether a profit objective               
          exists.  These factors are: (1) The manner in which the taxpayer            
          carries on the activity; (2) the expertise of the taxpayer or the           
          taxpayer's 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              
          losses with respect to the activity; (7) the amount of occasional           
          profits, if any, that are earned; (8) the financial status of the           
          taxpayer; and (9) any elements indicating personal pleasure or              
          recreation.  See sec. 1.183-2(b), Income Tax Regs.                          
               No single factor, nor even the existence of a majority of              
          factors, favoring or disfavoring the existence of a profit                  






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