Charlie Daniel Turner, Jr. and Sandra Lovell Turner - Page 12




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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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