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1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs. In
making this determination, more weight is accorded to objective
facts than to the taxpayer’s statement of intent. Engdahl v.
Commissioner, 72 T.C. 659, 666 (1979).
Factors to be considered in determining whether an activity
is engaged in for profit include: (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
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) the elements of personal pleasure or
recreation. All facts and circumstances are to be taken into
account and no single factor or group of factors is
determinative. Indep. Elec. Supply, Inc. v. Commissioner, 781
F.2d 724, 726-727 (9th Cir. 1986), affg. Lahr v. Commissioner,
T.C. Memo. 1984-472; Golanty v. Commissioner, 72 T.C. 411, 425-
426 (1979), affd. without published opinion 647 F.2d 170 (9th
Cir. 1981); sec. 1.183-2(b), Income Tax Regs.
We consider each of Rance’s and Zane’s activities
separately, beginning with petitioner Rance’s activity involving
cutting horses.
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