Robert A. and Sheila D. Routon - Page 5

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          profit motive.2  Skeen v. Commissioner, 864 F.2d 93, 94 (9th Cir.           
               To determine whether petitioners conducted their activity              
          for profit, we must weigh all facts and circumstances.  Golanty             
          v. Commissioner, 72 T.C. 411, 426 (1979), affd. without published           
          opinion 647 F.2d 170 (9th Cir. 1981).  Section 1.183-2(b), Income           
          Tax Regs., sets forth a nonexclusive list of nine factors to                
          guide courts in analyzing a taxpayer’s profit objective.  See               
          Elliott v. Commissioner, 90 T.C. 960 (1988), affd. without                  
          published opinion 899 F.2d 18 (9th Cir. 1990).  The nine 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 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 any, that are            
          earned; (8) the financial status of the taxpayer; and (9) the               
          elements of personal pleasure or recreation involved in the                 
          activity.  Sec. 1.183-2(b), Income Tax Regs.  Upon review of                
          these factors, we conclude that section 183 does not limit                  

               2Sec. 7491 is not applicable to this case.                             

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