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the requisite profit objective is a question of fact to be
resolved from all relevant facts and circumstances of the case.
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. In resolving this factual question, greater
weight is given to the objective facts than the taxpayer’s mere
statement of his intent. Siegel v. Commissioner, 78 T.C. 659,
699 (1982); sec. 1.183-2(a), Income Tax Regs.
The determination whether an activity is engaged in for
profit is made by reference to objective standards, taking into
consideration the facts and circumstances of the case. Sec.
1.183-2(a), Income Tax Regs. Section 1.183-2(b), Income Tax
Regs., provides a nonexclusive list of nine objective factors to
be considered in ascertaining a taxpayer’s intent. The factors
are: (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 the 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) any
elements indicating personal pleasure or recreation. Not all
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