Griffin v. The Queen, 96 DTC 1731 (TCC)

The taxpayer, who had a successful medical practice, was unable to deduct any of his losses incurred in respect of an import/export business given that the expenses were inordinately high and no income was received. Brulé TCJ. stated (at p. 1732): "There must be income, or the possibility of income to come, before there can be a reasonable expectation of profit."

The taxpayer, who had a successful medical practice, was unable to deduct any of his losses incurred in respect of an import/export business given that the expenses were inordinately high and no income was received. Brulé T.C.J. stated (at p. 1732): "There must be income, or the possibility of income to come, before there can be a reasonable expectation of profit."