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in which the taxpayer carried on the activity; (2) the expertise
of the taxpayer or his or her 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 loss 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) whether elements of personal
pleasure or recreation are involved. Sec. 1.183-2(b), Income Tax
Regs. No single factor controls. Brannen v. Commissioner, 722
F.2d 695, 704 (11th Cir. 1984), affg. 78 T.C. 471 (1982); sec.
1.183-2(b), Income Tax Regs.
C. Application of the Factors
1. Manner in Which the Taxpayer Conducts the Activity
Maintaining complete and accurate books and records,
conducting the activity in a manner substantially similar to that
of comparable businesses which are profitable, and making changes
in operations to adopt new techniques or abandon unprofitable
methods suggest that a taxpayer conducted an activity for profit.
Engdahl v. Commissioner, 72 T.C. 659, 666-667 (1979); sec. 1.183-
2(b)(1), Income Tax Regs.
Petitioners contend that petitioner operated the farm in a
businesslike manner. Petitioners also contend that petitioner
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