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profit” as any activity other than one for which deductions are
“allowable * * * under section 162 or under paragraph (1) or (2)
of section 212.” Essentially, the test for determining whether
an activity is engaged in for profit is whether the taxpayer
engages in the activity with the primary objective of making a
profit. Antonides v. Commissioner, 893 F.2d 656, 659 (4th Cir.
1990), affg. 91 T.C. 686 (1988). Although the expectation need
not be reasonable, the expectation must be bona fide. See Hulter
v. Commissioner, 91 T.C. 371, 393 (1988). Furthermore, in
resolving the question, greater weight is given to the objective
facts than to the taxpayer’s statement of intentions. See Thomas
v. Commissioner, 84 T.C. 1244, 1269 (1985), affd. 792 F.2d 1256
(4th Cir. 1986).
Section 1.183-2(b), Income Tax Regs., contains a
nonexclusive list of factors to be used in determining whether an
activity is engaged in for profit. These 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 assets used in the activity may appreciate
in value; (5) the success of the taxpayer in carrying on similar
or dissimilar activities; (6) the history of income or losses
with respect to the activity; (7) the amount of occasional
profits, if any; (8) the financial status of the taxpayer; and
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