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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
issue.
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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