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T.C. 1086 (1987); Indep. Elec. Supply, Inc. v. Commissioner, 781
F.2d 724, 726 (9th Cir. 1986), affg. Lahr v. Commissioner, T.C.
Memo. 1984-472.
Factors to be considered in determining whether an activity
is engaged in for profit include: (1) The manner in which the
taxpayer carries on the activity, (2) the expertise of the
taxpayer or her advisers, (3) the time and effort expended 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, which are earned, (8) the financial status of
the taxpayer, and (9) the elements of personal pleasure or
recreation. Indep. Elec. Supply, Inc. v. Commissioner, supra at
726-727; Antonides v. Commissioner, 91 T.C. 686, 694 n.4 (1988),
affd. 893 F.2d 656 (4th Cir. 1990); Golanty v. Commissioner, 72
T.C. 411, 426 (1979), affd. without published opinion 647 F.2d
170 (9th Cir. 1981); sec. 1.183-2(b), Income Tax Regs. No single
factor or group of factors is determinative. Golanty v.
Commissioner, supra at 426; Dunn v. Commissioner, 70 T.C. 715,
720 (1978), affd. 615 F.2d 578 (2d Cir. 1980); sec. 1.183-2(b),
Income Tax Regs. A final determination is made only after
considering all facts and circumstances. Indep. Elec. Supply,
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