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233 (1983). Greater weight is given to objective facts than to
the parties’ mere statements of intent. Engdahl v. Commissioner,
72 T.C. 659, 666 (1979). In determining whether an activity was
entered into for profit, the following factors are considered:
(1) The manner in which the taxpayers carried on the activity;
(2) the expertise of the taxpayers or their advisers; (3) the
time and effort expended by the taxpayers in carrying on the
activity; (4) an expectation that the assets used might
appreciate in value; (5) the success of the taxpayer in carrying
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 earned; (8) the financial status of
the taxpayer; and (9) the existence of elements of personal
pleasure in carrying out the activity. Sec. 1.183-2(b), Income
Tax Regs.
On this record, the Court concludes that the purchase of the
condominium and lot was not engaged in for profit, either from
business or investment. The Court reaches this conclusion based
on petitioner and Mr. Blodgett’s lack of expertise in the real
estate business, their insufficient time and effort expended in
carrying out any rental of the condominium, a lack of market
analysis on the appreciation potential of the property, and the
lack of credibility of the witnesses at trial. Although
petitioner claimed she and Mr. Blodgett purchased the Florida
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