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limitations of section 183, the taxpayer must show that he
engaged in the activity with an actual and honest objective of
making a profit. Keanini v. Commissioner, 94 T.C. 41, 46 (1990);
Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without
opinion 702 F.2d 1205 (D.C. Cir. 1983); Lopez v. Commissioner,
T.C. Memo. 2003-142. Although a reasonable expectation of a
profit is not required, the taxpayer’s profit objective must be
“actual and honest”. Dreicer v. Commissioner, supra at 645; sec.
1.183-2(a), Income Tax Regs. Whether a taxpayer has an actual
and honest profit objective is a question of fact to be resolved
from all the relevant facts and circumstances. Keanini v.
Commissioner, supra at 46; Lopez v. Commissioner, supra; sec.
1.183-2(a), Income Tax Regs. Greater weight is given to
objective facts than to a taxpayer’s statement of intent.
Keanini v. Commissioner, supra at 46; Dreicer v. Commissioner,
supra at 645; sec. 1.183-2(a), Income Tax Regs. As stated
earlier, the taxpayer bears the burden of establishing the
requisite profit objective. Rule 142(a); Keanini v.
Commissioner, supra at 46; Lopez v. Commissioner, supra.
Regulations promulgated under section 183 provide the
following nonexclusive list of factors which normally should be
considered in determining whether an activity was engaged in for
profit: (1) The manner in which the taxpayer carried on the
activity; (2) the expertise of the taxpayer or his advisers; (3)
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