Epic Associates 84-III, William C. Griffith, Jr. - Page 73




                                       - 157 -                                        
             activity was engaged in for profit:  (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 expectations that 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 of personal pleasure               
             or recreation.  See sec. 1.183-2(b), Income Tax Regs.                    
                  The properties purchased by EA 83-XII and EA 84-III                 
             were highly leveraged and produced operating losses.  The                
             offering memorandum issued by each partnership disclosed                 
             the fact that the partnership would incur such operating                 
             losses and that the properties had to appreciate in value                
             in order for an investor to realize a profit.  The offering              
             memorandum issued for EA 83-XII projected a break-even                   
             appreciation rate of 7.99 percent, and the offering memo-                
             randum for EA 84-III projected a break-even appreciation                 
             rate of 9.15 percent.  The appreciation rates required for               
             a profit were high, but there is nothing in the record of                








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