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activities; (6) the taxpayer’s history of income or loss 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) whether elements of personal pleasure or recreation are
involved. Id.
No one factor or set of factors is controlling, nor is the
existence of a majority of factors favoring or disfavoring a
profit motive necessarily controlling. Hendricks v.
Commissioner, 32 F.3d 94, 98 (4th Cir. 1994), affg. T.C. Memo.
1993-396; Brannen v. Commissioner, 722 F.2d 695, 704 (11th Cir.
1984), affg. 78 T.C. 471 (1982); sec. 1.183-2(b), Income Tax
Regs. The individual facts and circumstances of each case are
the primary test. Keanini v. Commissioner, supra at 46; Allen v.
Commissioner, 72 T.C. 28, 34 (1979); sec. 1.183-2(b), Income Tax
Regs.
C. Application of the Factors
1. The Manner in Which the Taxpayer Conducts the
Activity
We begin by examining the manner in which petitioner carried
on the farming activity. Carrying on an activity in a
businesslike manner may indicate a profit objective. Sec. 1.183-
2(b)(1), Income Tax Regs. In determining whether a taxpayer
conducted an activity in a businesslike manner, we consider
whether the taxpayer maintained complete and accurate books and
records and also whether changes were attempted in an effort to
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