Spencer v. R., [1998] 2 C.T.C. 2758 -- text
Rowe T.C.J.:
1 The appellant appealed with respect to his 1992, 1993 and 1994 taxation years. During those years he claimed business losses in the amounts of $37,219, $36,510 and $34,016 respectively.
2 The Minister of National Revenue disallowed the deductions of the losses claimed on the basis that during those years there was no reasonable expectation of profit.