LARO, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Petitioners petitioned the Court to redetermine deficiencies of $3,945, $1,875, and $2,858 in their Federal income taxes for 2005, 2006, and 2007, respectively. We decide whether petitioner Shawn Colleen Blanchette's (Ms. Blanchette) activity of selling science fiction memorabilia was an "activity not engaged in for profit" under section 183. We hold that Ms. Blanchette was not engaged in her activity for profit.

Some of the facts have been stipulated and are so found. The stipulated facts and the exhibits submitted therewith are incorporated by this reference.

Petitioners David Lee Blanchette 2011 Tax Ct. Summary LEXIS 15">*16 (Mr. Blanchette) and Ms. Blanchette resided in Las Vegas, Nevada, when their petition was filed. Mr. Blanchette was a software engineer who earned $77,145, $82,925, and $86,238 in 2005, 2006, and 2007, respectively. Ms. Blanchette became an avid reader of science fiction literature in 1976. Since that time, her passion for science fiction has grown steadily, and she has now been a collector of related memorabilia for more than 20 years. As early as 1987, Ms. Blanchette has bought and sold science fiction memorabilia retail.

In 1992 Ms. Blanchette formed and operated a proprietorship under the name A Wrinkle in Time (AWIT). From 1992 through 1995 Ms. Blanchette operated AWIT as a retail store in Santa Clara, California, leasing space and obtaining a business license to do so. Ms. Blanchette was the primary business owner and was intimately involved with all aspects of the business. On average, she worked at her store 14 hours per day, 7 days a week. Ms. Blanchette aggressively promoted AWIT locally with newspaper advertisements and regionally at science fiction conventions. Although Ms. Blanchette adopted a business plan in 1993 to transform AWIT into a partnership that could further 2011 Tax Ct. Summary LEXIS 15">*17 penetrate the science fiction memorabilia market, she never executed that plan. Despite Ms. Blanchette's efforts, her collectibles activity generated losses from 1992 through 1995.

In 1996 Ms. Blanchette relocated to Sunnyvale, California, where she operated AWIT as a retail store in leased space until 2001. During that time, Ms. Blanchette developed a Web site to sell her collection to online customers. Although she adopted a second business plan in 2000 to rebrand AWIT's online image, Ms. Blanchette did not bring that plan to fruition. She continued to incur losses from 1996 through 2001.

In 2001 Ms. Blanchette relocated to Las Vegas, Nevada. From 2002 through 2005 Ms. Blanchette sold science fiction memorabilia mostly online and at conventions. During that time Ms. Blanchette rented warehouse space to store her collection; and although the warehouse was generally not open to the public, she would sometimes show that collection to potential customers. Ms. Blanchette incurred losses from 2002 through 2005.

In 2005 petitioners inherited real estate (second home) from Mr. Blanchette's mother. Ms. Blanchette subsequently moved her collection from the warehouse to the second home and used 2011 Tax Ct. Summary LEXIS 15">*18 that home exclusively as a storage unit for her collection. Ms. Blanchette continued to add to her collection while also selling items online and at conventions with the help of Mr. Blanchette.

Ms. Blanchette valued the collection in 2005, 2006, and 2007 at $279,369, $294,166, and $299,560, respectively. She provided a generalized list of the items making up that collection, a sampling of which is as follows:

Ms. Blanchette did not insure her collection and states that some of the comic books and trading cards are worthless.

During 2005, 2006, and 2007 (subject years) Ms. Blanchette's collectibles activity generated gross receipts of $78,094, $82,428, and $89,525, respectively. Petitioners claimed losses from the operation of their collectibles activity on the Schedules C, Profit or Loss From Business, 2011 Tax Ct. Summary LEXIS 15">*19 attached to their Federal income tax returns as follows:

Ms. Blanchette's collectibles activity has not yielded a net financial profit during any year from 1992 through 2007, and total losses are estimated to be between $300,000 and $350,000.²

During the subject years, Ms. Blanchette devoted between 6 and 8 hours per day, 7 days a week, to her collectibles activity. On average, Ms. Blanchette would spend 200 days per year working out of her home, during which time she processed orders, responded to customers' inquiries, verified inventory, and prepared for conventions. On average, petitioners attended 18 conventions per year. In 2005, 2006, and 2007 petitioners spent 119, 78, and 96 days, respectively, driving to and selling at various conventions. On average, they drove 650 miles per day for 14 hours per day in order to attend these conventions. Once there, 2011 Tax Ct. Summary LEXIS 15">*20 petitioners would typically work 11.5 hours per day taking no breaks for meals. Petitioners would display the collection on two to five tables and paid approximately $300 per table.

For the subject years Ms. Blanchette kept spreadsheets of the income and expenses related to her collectibles activity. She also maintained a separate checking account and credit card though she did not engage in direct advertising. Ms. Blanchette presented various State tax forms and statements which she received between 2007 and 2009.

Respondent issued to petitioners a notice of deficiency dated January 22, 2009, disallowing petitioners' deductions for Schedule C expenses for each of the subject years. Respondent determined that the expenses reported on Schedules C were not allowable as trade or business expenses because petitioners did not establish that AWIT was a bona fide business venture entered into for profit. Petitioners petitioned the Court, and on October 27, 2010, a trial was held in Las Vegas, Nevada. Ms. Blanchette was the only witness to testify.

Respondent disallowed petitioners' Schedule C expense deductions for the subject years because respondent determined that Ms. Blanchette's 2011 Tax Ct. Summary LEXIS 15">*21 collectibles activity was an activity not engaged in for profit within the meaning of section 183. Petitioners argue generally that those expenses were deductible as section 162 ordinary and necessary business expenses incurred in connection with Ms. Blanchette's trade or business. For the reasons set forth below, we hold for respondent.

The Commissioner's determinations in a notice of deficiency are presumed correct, and the taxpayer bears the burden of proving that those determinations are in error. Rule 142(a)(1); Welch v. Helvering,290 U.S. 111">290 U.S. 111, 290 U.S. 111">115 (1933). Pursuant to section 7491(a), the burden of proof as to factual matters may shift to the Commissioner under certain circumstances. Petitioners have not alleged that section 7491(a) applies, nor have they established their compliance with the substantiation and recordkeeping requirements of the Internal Revenue Code. See sec. 7491(a)(2)(A) and (B). Accordingly, petitioners bear the burden of proof.³

Section 183, which applies to activities engaged in by individuals, generally limits 2011 Tax Ct. Summary LEXIS 15">*22 deductions for an activity not entered into for profit to the amount of the activity's gross income. Sec. 183(b). Section 183(c) defines an activity not engaged in for profit as "any activity other than one with respect to which deductions are allowable for the taxable year under section 162 or under paragraph (1) or (2) of section 212."

Section 162 allows as a deduction all the ordinary and necessary expenses paid or incurred in carrying on an activity which constitutes a trade or business of the taxpayer. Section 212 allows as a deduction all the ordinary and necessary expenses paid or incurred in carrying on an activity which is for the (1) production or collection of income, or (2) management, conservation, or maintenance of property held for the production of income.

The Court of Appeals for the Ninth Circuit, to which an appeal in this case would lie but for the provisions of section 7463(b), has held that for a taxpayer's expenses to be deductible under section 162 or 212 (and thereby avoid the limitations of section 183), the taxpayer must demonstrate that his or her "predominant, primary or principal" objective in engaging in the activity was to realize an economic profit independent 2011 Tax Ct. Summary LEXIS 15">*23 of tax savings. Wolf v. Commissioner,4 F.3d 709">4 F.3d 709, 4 F.3d 709">713 (9th Cir. 1993), affg. T.C. Memo. 1991-212. The taxpayer's expectation of profit need not be reasonable, but it must be bona fide. See sec. 1.183-2(a), Income Tax Regs. The existence of such a profit objective is a question of fact to be determined based on the surrounding facts and circumstances. Golanty v. Commissioner,72 T.C. 411">72 T.C. 411, 72 T.C. 411">426 (1979), affd. without published opinion 647 F.2d 170">647 F.2d 170 (9th Cir. 1981); see also sec. 1.183-2(b), Income Tax Regs. While such an analysis necessarily requires an inquiry into the subjective intent of the taxpayer, we may also look to objective indicia to determine the taxpayer's true intent. See Indep. Elec. Supply, Inc. v. Commissioner,781 F.2d 724">781 F.2d 724, 781 F.2d 724">726 (9th Cir. 1986), affg. Lahr v. Commissioner,T.C. Memo. 1984-472; see also sec. 1.183-2(a), Income Tax Regs.

Section 1.183-2(b), Income Tax Regs., sets forth a nonexclusive list of nine factors to be considered when ascertaining a taxpayer's intent. These factors are: (1) The manner in which the taxpayer carries on the activity; (2) the expertise of the taxpayer in carrying on the activity; (3) the time and effort expended by the taxpayer in carrying 2011 Tax Ct. Summary LEXIS 15">*24 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 loss with respect to the activity; (7) the amount of occasional profits, if any, which are earned by the taxpayer; (8) the financial status of the taxpayer; and (9) elements of personal pleasure or recreation. No single factor is conclusive, and we may accord certain factors greater weight than others. 72 T.C. 411">Golanty v. Commissioner, supra at 426; Allen v. Commissioner,72 T.C. 28">72 T.C. 28, 72 T.C. 28">34 (1979); see also sec. 1.183-2(b), Income Tax Regs.

Ms. Blanchette testified that she had an honest objective in making a profit from her collectibles activity. She also testified that she has reinvented her business to make the collectibles activity more profitable. In determining whether Ms. Blanchette had the requisite profit objective to avoid the limitations of section 183, we give limited weight to her testimony and greater weight to the objective factors listed above. Keanini v. Commissioner,94 T.C. 41">94 T.C. 41, 94 T.C. 41">46 (1990); Dreicer v. Commissioner,78 T.C. 642">78 T.C. 642 (1982), affd. without published opinion 2011 Tax Ct. Summary LEXIS 15">*25 702 F.2d 1205">702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs. We discuss each of the enumerated factors in turn.

That a taxpayer carries on an activity in a businesslike manner, maintains complete and accurate books and records, and changes operating methods to increase profitability may indicate that an activity is engaged in for profit. Engdahl v. Commissioner,72 T.C. 659">72 T.C. 659, 72 T.C. 659">666-667 (1979); sec. 1.183-2(b)(1), Income Tax Regs.

Petitioners separated their personal finances from Ms. Blanchette's collectibles activity and kept records of the income and expenses associated with that activity. Those records, however, basically served to substantiate the expenses which petitioners claimed on their Federal income tax returns. The existence of a separate bank account and credit card, we believe, facilitated the ease of recordkeeping. However, as we have previously recognized:

The purpose of maintaining books and records is more than to memorialize for tax purposes the existence of the subject transactions; it is to facilitate a means of periodically determining profitability and analyzing expenses such that proper cost saving measures might be 2011 Tax Ct. Summary LEXIS 15">*26 implemented in a timely and efficient manner. * * * [Burger v. Commissioner,T.C. Memo. 1985-523, affd. 809 F.2d 355">809 F.2d 355 (7th Cir. 1987).]