Michael D. and Suzan L. Storer - Page 10

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          78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205                
          (D.C. Cir. 1983).  The taxpayers’ expectation, however, need not            
          be a reasonable one.  Id. at 644-645; Golanty v. Commissioner, 72           
          T.C. 411, 425 (1979), affd. without published opinion 647 F.2d              
          170 (9th Cir. 1981); sec. 1.183-2(a), Income Tax Regs.  Whether             
          there is present the requisite intention of engaging in an                  
          activity with the objective of making a profit is a question of             
          fact that is to be resolved upon a consideration of all relevant            
          circumstances, with the greatest weight being given to the facts            
          rather than the taxpayers’ expression of their intent.  Dreicer             
          v. Commissioner, supra at 645; Golanty v. Commissioner, supra at            
          426; sec. 1.183-2(a) and (b), Income Tax Regs.  Therefore,                  
          irrespective of how ardently petitioners have stressed that they            
          always intended to make a profit from their photography activity,           
          whether or not their activity rose to a level that satisfies                
          their burden rests upon a consideration of all of the relevant              
          factors concerning their activity during the taxable years at               
               Section 1.183-2(b), Income Tax Regs., sets forth the                   
          following nonexclusive list of the relevant facts that we will              
          now consider: (1) The manner is which the taxpayers carry on the            
          activity; (2) the expertise of the taxpayers or their advisers;             
          (3) the time and effort expended by the taxpayers in carrying on            
          the activity; (4) the expectation that the assets used in the               

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