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Section 183(c) defines an activity not engaged in for profit
as “any activity other than one with respect to which deductions
are allowable for the taxable year under section 162 or under
paragraph (1) or (2) of section 212.” Deductions are allowable
under section 162 or under section 212(1) or (2) if the taxpayer
is engaged in the activity with the “actual and honest objective
of making a profit.” Ronnen v. Commissioner, 90 T.C. 74, 91
(1988); Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd.
without opinion 702 F.2d 1205 (D.C. Cir. 1983).
The existence of the requisite profit objective is a
question of fact that must be decided on the basis of the entire
record. Benz v. Commissioner, 63 T.C. 375, 382 (1974). In
resolving this factual question, greater weight is accorded
objective facts than a taxpayer's statement of intent. Westbrook
v. Commissioner, 68 F.3d 868, 875-876 (5th Cir. 1995), affg. T.C.
Memo. 1993-634; sec. 1.183-2(a), Income Tax Regs. For purposes
of deciding whether the taxpayer has the requisite profit
objective, profit means economic profit, independent of tax
savings. Surloff v. Commissioner, 81 T.C. 210, 233 (1983).
The regulations set forth a nonexhaustive list of factors
that may be considered in deciding whether a profit objective
exists. 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
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