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published opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-
2(a), Income Tax Regs. The taxpayer’s profit objective for each
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 at 46; Dreicer v. Commissioner, supra at 645;
Golanty v. Commissioner, 72 T.C. 411, 426 (1979), affd. without
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 his intent.
See Engdahl v. Commissioner, 72 T.C. 659, 666 (1979); sec. 1.183-
2(a), Income Tax Regs.
The following factors, which are nonexclusive, are
considered in the determination of 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-
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