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(1983); Feldman v. Commissioner, T.C. Memo. 1993-17, affd.
20 F.3d 1128 (11th Cir. 1994). Therefore, in the instant
cases, we look to the actions of the general partner, EPIC,
to determine whether both of the partnerships are subject
to section 183.
The determination whether an activity is engaged in
for profit is to be made by reference to objective
standards, taking into account all of the facts and
circumstances of each case. See sec. 1.183-2(a), Income
Tax Regs. No one factor is determinative in making this
determination. See sec. 1.183-2(b), Income Tax Regs.
Greater weight is to be given to objective facts than to
the taxpayer's statement of his or her interest. See sec.
1.183-2(a), Income Tax Regs.
As a preliminary matter, we note that none of the
parties to these cases contends that either partnership
conducted more than one activity. See generally sec.
1.183-1(d)(3), Income Tax Regs. For example, no party
contends that the holding of the residential properties for
appreciation and the renting of those properties by either
partnership were separate activities for purposes of
section 183.
The regulations list the following nine factors that
should be taken into account in determining whether an
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