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To deduct expenses of an activity under either section 162
or 212 (and thus avoid the limitations of section 183) a taxpayer
must show that he or she engaged in or carried on the activity
with an actual and honest objective of making a profit.
Antonides v. Commissioner, supra; Ronnen v. Commissioner, 90 T.C.
74, 91 (1988); Fuchs v. Commissioner, 83 T.C. 79, 97-98 (1984);
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. Although a reasonable expectation of profit is not
required, the taxpayer’s profit objective must be bona fide.
Hulter v. Commissioner, 91 T.C. 371, 393 (1988); Beck v.
Commissioner, 85 T.C. 557, 569 (1985); sec. 1.183-2(a), Income
Tax Regs. Whether a taxpayer has a bona fide profit objective is
a question of fact to be resolved from all the surrounding facts
and circumstances. Golanty v. Commissioner, 72 T.C. 411, 426
(1979), affd. without published opinion 647 F.2d 170 (9th Cir.
1981); sec. 1.183-2(b), Income Tax Regs. Greater weight is given
to objective facts than to a taxpayer’s mere statement of intent.
Thomas v. Commissioner, 84 T.C. 1244, 1269 (1985), affd. 792 F.2d
1256 (4th Cir. 1986); sec. 1.183-2(a), Income Tax Regs.
Section 1.183-2(b), Income Tax Regs., sets forth a
nonexclusive list of factors which should normally be taken into
account in determining whether the taxpayer has the requisite
profit objective. The factors are: (1) The manner in which the
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