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factors are applicable in every case, and no single factor, nor
even the existence of a majority of factors favoring or
disfavoring the existence of a profit objective, is controlling.
Abramson v. Commissioner, 86 T.C. 360, 371 (1986); sec. 1.183-
2(b), Income Tax Regs.
The manner in which a taxpayer carries on the activity is
one factor to consider in determining whether a profit objective
exists. Maintaining complete and accurate books and records,
carrying on the activity in a manner similar to other activities
that are profitable, and changing operating methods to adopt
new techniques or abandon unprofitable methods in a manner
consistent with an intent to improve profitability indicate that
a taxpayer conducted an activity for profit. See sec. 1.183-
2(b)(1), Income Tax Regs. Although petitioner did not maintain a
separate checking account for his fishing activity until 2003, he
maintained adequate books and records to determine the income and
expenses associated with his tournament bass fishing.
In response to respondent’s request for information,
petitioner prepared a Business Overview detailing the aims and
objectives of his bass fishing activity. The document
articulated the potential revenue that any participant who
competed in and won 12 of the biggest bass fishing tournaments
held by B.A.S.S. and FLW Outdoors might earn; however, the
document did not include a financial projection with respect to
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