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year in which the activity is conducted must be bona fide, taking
into account all of the facts and circumstances. See Keanini v.
Commissioner, supra; Dreicer v. Commissioner, supra at 645;
Golanty v. Commissioner, 72 T.C. 411, 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); sec. 1.183-2(a) and (b), Income Tax Regs. More
weight is given to objective facts than to the taxpayer’s
statement of intent. See Engdahl v. Commissioner, 72 T.C. 659,
666 (1979); sec. 1.183-2(a), Income Tax Regs.
The following nonexclusive factors are considered in
determining whether an activity is engaged in for profit:
(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 expended by the taxpayer in carrying on the
activity; (4) the expectation that 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, which are
earned; (8) the financial status of the taxpayer; and (9)
elements of personal pleasure or recreation. See sec. 1.183-
2(b), Income Tax Regs. No one factor is determinative, and our
conclusion with respect to petitioners’ profit objective does not
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