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No one factor is determinative in and of itself, and our
conclusion with respect to petitioner’s profit objective does not
depend upon merely counting up those factors that suggest the
presence of a profit motive and comparing the number to those
factors that indicate the opposite. Sec. 1.183-2(b), Income Tax
Regs. These factors are nonexclusive, and not every factor is
relevant in every case. Vandeyacht v. Commissioner, T.C. Memo.
1994-148; Borsody v. Commissioner, T.C. Memo. 1993-534, affd. per
curiam 92 F.3d 1176 (4th Cir. 1996); sec. 1.183-2(b), Income Tax
Regs.
Turning to the relevant factors enumerated in section 1.183-
2(b), Income Tax Regs., we find that petitioner’s gambling
activity was operated in a businesslike manner. Petitioner
regularly attended the horseraces at Yonkers. In addition to
keeping copies of betting slips and racing forms and programs,
petitioner kept detailed records with respect to his gambling
activity. Petitioner kept a detailed account of his daily
wagers, as well as a cumulative total of his yearly winnings and
losses. Petitioner also maintained numerous statistics for each
horserace in the form of “speed figures” and used this
information for handicapping horseraces. Petitioner reviewed
videotapes of the horseraces for further study. During the
taxable year in issue, petitioner also began to use a computer to
maintain a significant amount of his records with respect to his
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