Larry T. Cooper - Page 7

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          Westbrook v. Commissioner, 68 F.3d 868, 876 (5th Cir. 1995),                
          affg. per curiam T.C. Memo. 1993-634 (emphasis added).  If a                
          taxpayer engages in an activity without a profit objective,                 
          deductions attributable to the activity are allowed only to the             
          extent of the income derived from the activity.  Sec. 183(b)(2);            
          see Hager v. Commissioner, 76 T.C. 759, 781 (1981).                         
               The determination of whether an activity is engaged in for             
          profit is to be made by reference to objective standards, taking            
          into account all the facts and circumstances of each case.                  
          Brannen v. Commissioner, 78 T.C. 471, 506 (1982), affd. 722 F.2d            
          695 (11th Cir. 1984); Jasionowski v. Commissioner, 66 T.C. 312,             
          319 (1976); sec. 1.183-2(b), Income Tax Regs.  Greater weight is            
          given to the objective facts than to the taxpayer’s own                     
          statements of intent.  Sec. 1.183-2(a), Income Tax Regs.  The               
          burden of proof is on the taxpayer to show that he or she engaged           
          in an activity with the objective of realizing an economic                  
          profit.  Rule 142(a).                                                       
               Section 1.183-2(b), Income Tax Regs., sets forth a                     
          nonexclusive list of factors that should normally be taken into             
          account in determining whether the requisite profit objective has           
          been shown.  The factors are:  (1) Manner in which the taxpayer             
          carries on the activity; (2) the expertise of the taxpayer or his           
          advisers; (3) the time and effort expended by the taxpayer; (4)             
          expectation that assets used in activity may appreciate in value;           






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