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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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