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the activity is not the most significant aspect of the trade or
business analysis. More important is the taxpayer’s actual or
honest objective of making a profit. Keanini v. Commissioner, 94
T.C. 41, 46 (1990); Hulter v. Commissioner, 91 T.C. 371, 392
(1988); Dreicer v. Commissioner, 78 T.C. 642, 644-645 (1982),
affd. without published opinion 702 F.2d 1205 (D.C. Cir. 1983);
sec. 1.183-2(a), Income Tax Regs.
Although a reasonable expectation of a profit is not
required, the taxpayer’s profit objective must be actual and
honest. Dreicer v. Commissioner, supra at 645; sec. 1.183-2(a),
Income Tax Regs. Whether a taxpayer has an actual and honest
profit objective is a question of fact to be answered from all
the relevant facts and circumstances. Hulter v. Commissioner,
supra at 393; Hastings v. Commissioner, T.C. Memo. 2002-310; sec.
1.183-2(a), Income Tax Regs. Greater weight is given to
objective facts than to a taxpayer’s mere statement of intent.
Dreicer v. Commissioner, supra at 645; sec. 1.183-2(a), Income
Tax Regs. The taxpayer bears the burden of establishing he or
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