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circumstances. Antonides v. Commissioner, supra; Golanty v.
Commissioner, supra; Jasionowski v. Commissioner, 66 T.C. 312,
321 (1979). Greater weight is given to objective facts than to a
taxpayer’s mere statement of intent. Antonides v. Commissioner,
supra; Thomas v. Commissioner, 84 T.C. 1244, 1269 (1985), affd.
792 F.2d 1256 (4th Cir. 1986). Petitioners bear the burden of
proving the requisite intention. Rule 142(a). The parties do
not argue that the burden shifts to respondent under section
7491(a).
Section 1.183-2(b), Income Tax Regs., sets forth a
nonexclusive list of relevant factors which should normally be
considered in determining whether an activity is engaged in for
profit. The factors include: (1) The 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 in carrying on the activity, (4) the expectation that
assets used in 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, which are earned, (8) the financial status of the taxpayer,
and (9) the elements of personal pleasure or recreation. Sec.
1.183-2(b), Income Tax Regs; Antonides v. Commissioner, supra at
694 n.4; Golanty v. Commissioner, supra at 426. No single factor
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