Anke Lunsmann-Nolting - Page 7

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          “activity not engaged in for profit” as “any activity other than            
          one with respect to which deductions are allowable for the                  
          taxable year under section 162 or under paragraph (1) or (2) of             
          section 212.”                                                               
               An activity is engaged in for profit if the taxpayer                   
          entertained an actual and honest, even though unreasonable or               
          unrealistic, profit objective in engaging in the activity.                  
          Hulter v. Commissioner, 91 T.C. 371, 393 (1988); Ronnen v.                  
          Commissioner, 90 T.C. 74, 91 (1988) (taxpayer’s objective of                
          making a profit must be bona fide); sec. 1.183-2(a), Income Tax             
          Regs.                                                                       
               The determination of whether an activity is engaged in for             
          profit is to be made by reference to objective standards, taking            
          into account all the facts and circumstances of each case.                  
          Dreicer v. Commissioner, 78 T.C. 642, 644-645 (1982), affd.                 
          without opinion 702 F.2d 1205 (D.C. Cir. 1983); Jasionowski v.              
          Commissioner, 66 T.C. 312, 319 (1976); sec. 1.183-2(b), Income              
          Tax Regs.  Greater weight is given to the objective facts than to           
          the taxpayer’s own statements of intent.  Sec. 1.183-2(a), Income           
          Tax Regs.                                                                   
               Section 1.183-2(b), Income Tax Regs., sets forth a                     
          nonexclusive list of factors that should normally be taken into             
          account in determining whether the requisite profit objective has           
          been shown.  The factors are:  (1) Manner in which the taxpayer             
          carries on the activity; (2) the expertise of the taxpayer or his           




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