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expectation of profit is not required, the taxpayer’s objective
of making a profit must be bona fide. See Wittstruck v.
Commissioner, supra at 619; Elliott v. Commissioner, 84 T.C. 227,
236 (1985), affd. without published opinion 782 F.2d 1027 (3d
Cir. 1986). The Court gives greater weight to objective factors
in making the factual determination 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.
We consider several factors13 in determining whether
Mr. Lofstrom was engaged in the writing activity for profit,
including the manner in which he carried on the activity, the
time and effort he expended on the activity, the history of
income or loss with respect to the activity, and the amount of
13The Court generally considers nine nonexclusive factors
for determining whether taxpayers engaged in an activity for
profit. Sec. 1.183-2(b), Income Tax Regs. Petitioners here
failed to produce relevant evidence regarding many of the
factors, and we consequently confine our analysis to four of the
nine factors. The nine factors are: (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 activities for
profit; (6) the taxpayer’s history of income or losses with
respect to the activity; (7) the amount of occasional profits, if
any, which are earned; (8) the financial status of the taxpayer;
and (9) elements of personal pleasure or recreation. Id.
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