- 12 -
See Independent Elec. Supply, Inc. v. Commissioner, 781 F.2d 724,
726-727 (9th Cir. 1986), affg. Lahr v. Commissioner, T.C. Memo.
1984-472; Dreicer v. Commissioner, 78 T.C. 642, 644-645 (1982),
affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-
2(a), Income Tax Regs.
A nonexclusive list of factors set forth in the income tax
regulations guides our section 183 analysis by providing relevant
facts and circumstances to be considered in determining whether
the requisite profit objective has been shown. These factors
include: (1) The manner in which the taxpayer carried 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 taxpayer’s
history of income or loss with respect to the activity; (7) the
amount of occasional profit, if any, which is earned; (8) the
financial status of the taxpayer; and (9) whether elements of
personal pleasure or recreation are involved. See sec. 1.183-
2(b), Income Tax Regs. Although no one factor is conclusive, a
record of substantial losses over many years and the unlikelihood
of achieving a profit are indicative that an activity is not
engaged in for profit. See Hildebrand v. Commissioner, 28 F.3d
1024, 1027 (10th Cir. 1994), affg. Krause v. Commissioner, 99
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