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Commissioner, 90 T.C. 74, 91 (1988); Dreicer v. Commissioner, 78
T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205 (D.C.
Cir. 1983). While a taxpayer need not have a reasonable
expectation of profit, the facts and circumstances must
demonstrate that he or she entered into the activity, or
continued the activity, with the actual and honest objective of
making a profit. Taube v. Commissioner, 88 T.C. 464, 478 (1987);
Dreicer v. Commissioner, supra at 645. The taxpayer’s objective
to make a profit must be analyzed by looking at all the
surrounding facts. Dreicer v. Commissioner, supra at 645. These
facts are given greater weight than the taxpayer’s mere statement
of intent. Id.
Section 1.183-2(b), Income Tax Regs., provides a
nonexclusive list of relevant factors which should be considered
in determining whether the taxpayer has the requisite profit
objective. The factors are: (1) The manner in which the
taxpayer carries on the activity; (2) the expertise of the
taxpayer or 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, which are earned; (8) the financial status of
the taxpayer; and (9) any elements indicating personal pleasure
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