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analyzed by looking at all the surrounding facts. Dreicer v.
Commissioner, supra at 645. These facts are given greater weight
than the taxpayer’s mere statement of intent. Id.
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
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).
Petitioner did not carry on a business in a businesslike
fashion. She had no books or records, no records of students,
and no business plans. She had no gross receipts. She could not
make a profit because she did not charge for the alleged
services. She admitted that she intended to go into business
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