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that they entered into the activity, or continued the activity,
with the actual and honest objective of making a profit. Taube
v. Commissioner, 88 T.C. 464, 478 (1987); 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.
The taxpayer's motive to make a profit must be analyzed by
looking at all the surrounding objective facts. Id. at 645.
These facts are given greater weight than petitioner’s mere
statement of intent. Dreicer v. Commissioner, supra.
Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of relevant factors which should be considered
in determining whether the taxpayer has the requisite profit
objective. The factors are: (1) The manner in which the taxpayer
carries on the activity; (2) the expertise of the taxpayer or his
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, which are earned; (8) the financial status of the taxpayer;
and (9) any elements indicating personal pleasure or recreation.
Sec. 1.183-2(b), Income Tax Regs. These factors are not
applicable or appropriate in every case. Abramson v.
Commissioner, 86 T.C. 360, 371 (1986).
In determining whether petitioner was engaged in the apple
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