Robertson
J.A.:
We
are
all
of
the
view
that
Judge
Sarchuck
did
not
err
in
holding
that
the
appellant
taxpayers
had
no
reasonable
expectation
of
profit
for
the
1983,
1984
and
1985
taxation
years.
It
is
true
that
the
decision
of
this
Court
in
Tonn
v.
R.,
[1996]
2
F.C.
73
(Fed.
C.A.)
was
not
decided
until
after
Judge
Sarchuck
released
his
decision.
Nonetheless,
we
have
not
been
persuaded
that
anything
that
was
decided
in
that
case
warrants
our
interference
in
the
present
circumstances.
The
reality
is
that
the
taxpayers
undertook
a
venture
without
sufficient
capital
and
a
business
plan.
The
fact
that
they
rented
the
cabins
in
question
to
their
relatives
is
also
a
factor
which
cannot
be
ignored.
For
these
reasons,
the
appeals
must
be
dismissed
with
one
set
of
costs.
Appeals
dismissed.
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