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requirements of that section.
The test to determine whether a taxpayer conducted an
activity for profit is whether he or she engaged in the activity
with an actual and honest objective of earning a profit. Keanini
v. Commissioner, 94 T.C. 41, 46 (1990); Dreicer v. Commissioner,
78 T.C. 642, 644-645 (1982), affd. without published opinion 702
F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs.
Although a reasonable expectation of profit is not required, the
taxpayer’s profit objective must be bona fide, as determined from
a consideration of all the facts and circumstances. Keanini v.
Commissioner, supra; Dreicer v. Commissioner, supra at 645;
Golanty v. Commissioner, 72 T.C. 411, 425-426 (1979), affd.
without published opinion 647 F.2d 170 (9th Cir. 1981); Bessenyey
v. Commissioner, 45 T.C. 261, 274 (1965), affd. 379 F.2d 252 (2d
Cir. 1967). More weight is given to objective facts than to the
taxpayer’s statement of his or her intent. Engdahl v.
Commissioner, 72 T.C. 659, 666 (1979); sec. 1.183-2(a), Income
Tax Regs.
The regulations under section 183 provide nine nonexclusive
factors to be used in determining whether a taxpayer is
conducting an activity with the intent to make a profit. Sec.
1.183-2(b), Income Tax Regs. The factors are: (1) The manner in
which the taxpayer carried on the activity; (2) the expertise of
the taxpayer or his or her advisers; (3) the time and effort
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