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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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