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35 (1987). If an individual engages in an activity without the
objective for profit, section 183 generally limits allowable
deductions attributable to the activity to the extent of gross
income generated by such activity. Sec. 183(b).
Although “it is sufficient if the taxpayer has a bona fide
expectation of realizing a profit, regardless of the
reasonableness of such expectation”, whether or not a taxpayer is
engaged in the activity for profit depends on all the surrounding
facts and circumstances of the case. Golanty v. Commissioner, 72
T.C. 411, 425-26 (1979), affd. without published opinion 647 F.2d
170 (9th Cir. 1981). Greater weight is given to objective facts
than to a taxpayer’s mere statement of intent. Dreicer v.
Commissioner, 78 T.C. 642, 645 (1982), affd. without opinion 702
F.2d 1205 (D.C. Cir. 1983).
The regulations set forth the following nonexclusive factors
to consider in determining whether an activity is engaged in for
profit. These factors are: (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 the 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 losses with
respect to the activity; (7) the amount of occasional profits, if
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