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activity; (2) the expertise of the taxpayer or his advisers;
(3) the time and effort spent 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; (8) the
financial status of the taxpayer; and (9) elements of personal
pleasure or recreation. None of these factors is controlling in
and of itself, and a decision as to a taxpayer’s intent is not
governed by a numerical preponderance of the factors. Golanty v.
Commissioner, supra at 426; Allen v. Commissioner, 72 T.C. 28, 34
(1979); sec. 1.183-2(b), Income Tax Regs.
Petitioner relies primarily on her testimony to establish
both her proposed findings of disputed facts and her objective as
to the horse activity. We give petitioner’s uncorroborated
testimony limited weight for that purpose. See Ruark v.
Commissioner, 449 F.2d 311, 312 (9th Cir. 1971), affg. per curiam
T.C. Memo. 1969-48; Clark v. Commissioner, 266 F.2d 698, 708-709
(9th Cir. 1959), affg. in part and remanding T.C. Memo. 1957-129;
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Our perception
of petitioner while viewing her testifying at trial coupled with
our review of the record leads us to discount her uncorroborated
testimony. For the most part, she testified generally, vaguely,
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