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Groetzinger, 480 U.S. 23, 35 (1987). The taxpayer’s expectation
of profit need not be reasonable; however, a good faith
expectation of profit is required. Burger v. Commissioner, 809
F.2d 355, 358 (7th Cir. 1987), affg. T.C. Memo. 1985-523; Golanty
v. Commissioner, 72 T.C. 411, 425-426 (1979), affd. without
published opinion 647 F.2d 170 (9th Cir. 1981). All the facts
and circumstances must be considered, and more weight is given to
objective facts than to the taxpayer’s statement of his intent.
Engdahl v. Commissioner, 72 T.C. 659, 666 (1979).
In determining whether petitioner possessed the requisite
profit motive under section 162(a), we look to the factors set
forth in section 183. Osteen v. Commissioner, 62 F.3d 356, 358
(11th Cir. 1995), affg. in part and revg. in part T.C. Memo.
1993-519. The regulations promulgated under section 183, section
1.183-2(b), Income Tax Regs., set forth a nonexclusive list of
factors, which include: (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 assets used in
the activity may appreciate in value; (5) the success of the
taxpayer in carrying on 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) the
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