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fide. See Golanty v. Commissioner, supra at 425-426. Although
our analysis focuses on the subjective intention of the taxpayer,
greater weight is given to objective facts than to a taxpayer’s
mere statement of intent. See Independent Elec. Supply, Inc. v.
Commissioner, 781 F.2d 724, 726 (9th Cir. 1986), affg. Lahr v.
Commissioner, T.C. Memo. 1984-472; Dreicer v. Commissioner, 78
T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205 (D.C.
Cir. 1983); Churchman v. Commissioner, 68 T.C. 696, 701 (1977);
sec. 1.183-2(a), Income Tax Regs. Petitioner bears the burden of
proving he had the requisite profit objective. See Rule 142(a);
Golanty v. Commissioner, supra at 426.
Section 1.183-2(b), Income Tax Regs., sets forth a
nonexclusive list of factors to 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 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 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)
elements of personal pleasure or recreation. No single factor is
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