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170 (9th Cir. 1981); sec. 1.183-2(a), Income Tax Regs. While a
reasonable expectation of profit is not required, the taxpayer's
objective of making a profit must be bona fide. See Elliott v.
Commissioner, 84 T.C. 227, 236 (1985), affd. without published
opinion 782 F.2d 1027 (3d Cir. 1986). In making this factual
determination, the Court gives greater weight to objective
factors than to a taxpayer's mere statement of intent. See
Indep. Elec. Supply, Inc. v. Commissioner, 781 F.2d 724 (9th Cir.
1986), affg. Lahr v. Commissioner, T.C. Memo. 1984-472; Dreicer
v. Commissioner, 78 T.C. 642, 645 (1982), affd. without opinion
702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs.
Section 1.183-2(b), Income Tax Regs., sets forth nine
nonexclusive factors that should be considered in determining
whether a taxpayer is engaged in a venture with a profit
objective. They 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 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 loss with
respect to the activity; (7) the amount of occasional profits
that are earned; (8) the financial status of the taxpayer; and
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