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satisfied, however, that petitioner looked to this activity for a
production of income for his livelihood.2
Furthermore, generally, under section 183(a) and (b) an
individual is not allowed deductions attributable to an activity
“not engaged in for profit” except to the extent of gross income
generated by the activity. Section 183(c) defines an activity
“not engaged in for profit” as any activity other than one for
which deductions are “allowable * * * under section 162 or under
paragraph (1) or (2) of section 212.” Essentially the test for
determining whether an activity is engaged in for profit is
whether the taxpayer engages in the activity with the primary
objective of making a profit. See Antonides v. Commissioner, 893
F.2d 656, 659 (4th Cir. 1990), affg. 91 T.C. 686 (1988).
Although the expectation need not be reasonable, the expectation
must be bona fide. See Hulter v. Commissioner, 91 T.C. 371, 393
(1988). Furthermore, in resolving the question, greater weight
is given to the objective facts than to the taxpayer’s statement
of intentions. See Thomas v. Commissioner, 84 T.C. 1244, 1269
(1985), affd. 792 F.2d 1256 (4th Cir. 1986).
Section 1.183-2(b), Income Tax Regs., contains a
nonexclusive list of factors to be used in determining whether an
activity is engaged in for profit. These factors are: (1) The
2 We note that petitioner did not argue or establish that he
satisfied the requirements of sec. 7491(a).
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