- 17 -
"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 taxpayer's expectation of profit need not be a
reasonable one but there must be a good faith objective of making
a profit. See Dreicer v. Commissioner, supra at 645; sec. 1.183-
2(a), Income Tax Regs. The determination of whether the
requisite profit objective exists is based on all the surrounding
facts and circumstances. See Golanty v. Commissioner, 72 T.C.
411, 426 (1979), affd. without published opinion 647 F.2d 170
(9th Cir. 1981); sec. 1.183-2(b), Income Tax Regs. Greater
weight is to be given to the objective facts than the taxpayer's
mere statement of his intent. See Dreicer v. Commissioner, supra
at 645; sec. 1.183-2(a), Income Tax Regs. The taxpayer has the
burden of proving the requisite intention and that respondent's
determination that the activity was not engaged in for profit is
incorrect. See Rule 142(a); Welch v. Helvering, 290 U.S. 111
(1933).
Although the question of the taxpayer's profit motive is a
subjective one, objective indicia may be considered to establish
the taxpayer's true intent. See sec. 1.183-2(a), Income Tax
Regs. Section 1.183-2(b), Income Tax Regs., sets forth a
nonexclusive list of nine objective factors to be considered in
ascertaining the taxpayer's intent. These factors are: (1) The
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