Petitioners have conceded that the section 6651 addition to tax for failing to file their return in a timely manner is applicable to their 1988 joint income tax return and to Mr. Dawson's 1989 individual income tax return. For purposes of section 183, a taxpayer engages in an activity for profit if he entered into the activity with the actual and honest objective of making a profit. The taxpayer's expectation of profit need not be reasonable, but he or she must have a good faith objective of making a profit. The determination of whether a taxpayer conducted the activity for profit is made based on the facts and circumstances of the case. Although the purpose of the inquiry is to ascertain the taxpayer's subjective intent, greater weight is given to objective facts than to the taxpayer's statements of intent.
Petitioners bear the burden of proving they intended to make a profit.
Beck v. Commissioner, supra at 570. See Independent Elec. No single factor is dispositive. Golanty v. Commissioner, supra at 426. After considering the evidence in this case, we conclude that petitioners engaged in the Activity with the actual and honest objective of making a profit.