James A. and Corlis L. Perry - Page 6

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          (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.                                                             
               The regulations provide 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 or recreation.  Sec. 1.183-2(b), Income Tax               
          Regs.  These factors are not applicable or appropriate in every             
          case.  Abramson v. Commissioner, 86 T.C. 360, 371 (1986).  The              






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