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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. See sec. 1.183-
2(b), Income Tax Regs. No single factor controls. See Osteen v.
Commissioner, supra at 358; 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.
B. 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
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.
See Engdahl v. Commissioner, 72 T.C. 659, 666-667 (1979); sec.
1.183-2(b)(1), Income Tax Regs.
There is no evidence establishing that petitioner had a
business plan. Petitioner wanted to sell evergreen trees and
some of the trees that were growing indigenously on the land to
nurseries and to individuals, and he knew that he could not sell
the trees he planted for 10 years. However, the fact that he
planted trees without keeping records of the number planted and
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