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Inc. v. Commissioner, supra at 727; Antonides v. Commissioner,
supra at 694; Golanty v. Commissioner, supra at 426.
“The proper focus of the test * * * is the taxpayer’s
subjective intent. * * * However, objective indicia may be used
to establish that intent.” Skeen v. Commissioner, supra at 94;
see also Wolf v. Commissioner, supra at 713; Indep. Elec. Supply,
Inc. v. Commissioner, supra at 726. The expectation of making a
profit need not be reasonable. Beck v. Commissioner, 85 T.C.
557, 569 (1985); Dreicer v. Commissioner, 78 T.C. 642, 645
(1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983);
Golanty v. Commissioner, supra at 425-426. However, greater
weight is given to objective facts than to a taxpayer’s self-
serving statement of intent. Indep. Elec. Supply, Inc. v.
Commissioner, supra; Antonides v. Commissioner, supra; Thomas v.
Commissioner, 84 T.C. 1244, 1269 (1985), affd. 792 F.2d 1256 (4th
Cir. 1986).
Respondent determined that petitioner did not engage in her
horse activity with an intent to derive a profit and therefore
disallowed the Schedule C loss deductions. Petitioner contends
that she engaged in her horse activity with an intent to derive a
profit and is therefore entitled to deduct from her gross income
Schedule C losses relating to that activity. To make our
determination, we address the nine factors found in section
1.183-2(b), Income Tax Regs.
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