Thomas W. and Pamela A. Hill - Page 9

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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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