Robertson
J.A.:
The
principle
issue
raised
on
this
judicial
review
application
is
whether
the
deduction
of
certain
rental
losses
arising
from
the
rental
of
two
residential
properties
were
properly
disallowed.
In
our
respectful
view,
Judge
Rip
did
not
err
in
concluding
on
the
evidence
that
the
taxpayer
had
failed
to
satisfy
the
reasonable
expectation
of
profit
test
as
articulated
in
the
jurisprudence.
None
of
the
factual
errors
alleged
by
the
taxpayer,
assuming
them
to
be
true,
would
in
our
opinion,
have
affected
the
ultimate
disposition
of
this
case.
Accordingly,
the
application
for
judicial
review
will
be
dismissed.
Application
dismissed.
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