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This was the only connection between his egg business and his small farming operation at the nine-acre site. ...

Paragraph 2 of the reply to the notice of appeal sets out the facts and assumptions relied on by the respondent: (a) The appellant carried on a farming operation wherein he purchased and sold or otherwise disposed of standard-bred rare* [1] horses throughout the period at issue as follows: Horse Date Date Purchase Date Date Selling Purchased Price Sold Sold Price Eartha October 1980 $2,500.00 February 1984 $ 300.00 Osborne Jefferson January 1981 $1,000.00 June 1981 $ 500.00 Fortune Tarbrush January 1982 $2,500.00 June 1982 $1,500.00 Hoodsland January 1982 $ 750.00 Given away to son Popout (b) The appellant earned $364.00 in purse money in 1982 and $300.00 in purse money for 1983, earned from racing these horses; (c) The appellant had no prior experience in the area of horse racing before he purchased these horses; (d) The appellant was employed in 1982 as a field-erection superintendent and in 1983 he worked part-time as a driver and claimed unemployment insurance benefits; (e) Throughout this period, the appellant lacked sufficient capital to expand his operation into a viable business and no profit was ever earned from the pursuit of this hobby; (f) The nature and extent of the appellant's activities indicate that the expenses claimed by the appellant were not incurred in connection with a business carried on for profit or with a reasonable expectation of profit; (g) The expenses claimed by the appellant in the year 1982 and 1983 taxation year in respect of which he claimed deductions in computing his income for those years were expenses of a personal nature and were not expenses incurred for the purpose of gaining or producing income from a business or property. ...

The variable expenses incurred during 1982 in connection with this part of the operations were $5,549. ...

This argument rested on evidence given by the appellant in which he described his wife as an "active shareholder" of Peeltown and stated that she does now and has in the past looked after all bookkeeping and banking chores in connection with the company's business. ...

“personal or living expenses” includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, 4.02. ...

Certain instances when he acted decisively and directly in connection with his work as well as some indication of the investigative reporting and jornalism which he initiated on his own, were cited as examples of such independence. ...

Dealing firstly with subparagraph 8(l)(f)(i), (and I will paraphrase), certain expenses are deductible (by the taxpayer) where they are incurred in connection with the selling of property for his employer and where under the contract of employment the employee was required to pay his own expenses. ...

Mr Denis Lessard, a Department of National Revenue auditor since 1974, stated that he had begun auditing the appellant’s hotel accounts in 1980 in connection with a disposition by the appellant of one of his properties. ...

The business, as indicated, had been terminated and the carrying charges from the financial obligations incurred in connection therewith, could not be redirected and deducted from other income, such as employment income. ...

They read as follows: 18. (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (h) personal or living expenses of the taxpayer except travelling expenses (including the entire amount expended for meals and lodging) incurred by the taxpayer while away from home in the course of carrying on his business; 248. (1) In this Act, “personal or living expenses” includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries; 4.02 Analysis 4.02.1 The crux of the matter is whether there was a reasonable expectation of profit in the appellant’s research and writing activity during the years 1977 to 1980 inclusive. ...