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(c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; [14]          In the present appeal, it has been stated by way of assumption that the rental building was not a residential complex or unit and was not used as a place of residence by the tenant. ...

"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. [3]            The assumptions upon which the Minister assessed the appellant are the following. ...

Reasons for Judgment Watson, D.J.T.C.C. [1]            This appeal was heard at Trois-Rivières, Quebec, on June 15, 2001, under the informal procedure. [2]            In computing his income for the 1993, 1994, 1995 and 1996 taxation years, the appellant deducted $26,039, $23,484, $11,630 and $12,485, respectively, as losses from farming activities. [3]            By notices of reassessment dated September 22, 1997, the Minister of National Revenue ("the Minister") disallowed the amounts of $26,039, $23,484, $11,630 and $12,485 respectively as losses in computing the appellant's income for the 1993, 1994, 1995 and 1996 taxation years. [4]            In making the reassessments, the Minister assumed the following facts, inter alia: [TRANSLATION] (a)            the appellant is a nurse in a remote area who reported the following amounts as employment income during the years at issue:                 (i)                             1993                                         $102,175                 (ii)                            1994                                         $74,070                 (iii)                           1995                                         $54,053                 (iv)                           1996                                         $67,593; (b)            in 1991, the appellant paid $60,000 to purchase a farm that had been in a state of neglect for about 10 years; (c)            the appellant borrowed $40,000 to purchase the said farm; (d)            the farm is located at 7 Chemin Doucet in Saint-Mathieu-du-Parc; (e)            the appellant intends to engage in fruit and berry farming, sell maple products, provide rental accommodations for holidays and carry on logging activities; (f)             during the years at issue, the appellant spent about three months working on the farm; (g)            in 1994, the appellant took out a loan of $85,000 to build his house; (h)            the gross annual income during the years at issue was almost nil:                 (i)                             1993                                         $1,040                 (ii)                            1994                 (iii)                           1995                                         $1,092                 (iv)                           1996                                         $1,100; (i)             the appellant does not know the source of the gross annual income he reported; (j)             the appellant has not done any profitability analysis and is relying on the farm's potential; (k)            the appellant has no experience operating a farm; (l)             the appellant had no reasonable expectation of profit in running the farm during the period from 1993 to 1996; and (m)           the expenses paid each year in connection with the farm were the appellant's personal or living expenses and were not incurred by him for the purpose of gaining or producing farming income. [5]            At the hearing, the agent for the appellant, Maurice Magny, admitted the facts alleged in subparagraphs (a) to (h) and (k) and denied the facts alleged in subparagraphs (i), (j), (l) and (m). [6]            The appellant was the only person who testified when the appeal was heard. ...

(Exhibit A-4). [7]            Despite my numerous attempts to have the appellant make a direct connection with the loans, he was never able to do so. ...

He said further that because he did not believe these to be deductible he disposed of all records in connection with the activities. ...

The Minister of National Revenue (the Minister) has reassessed him to disallow these amounts, taking the position that the Appellant and his wife, during the years under appeal, had no reasonable expectation of making a profit from the sale of Amway products, and that this activity on their part therefore did not constitute a business, and so was not a source of income within the meaning of that expression in section 3 of the Act, with the result that the losses from it are not available to offset other income. [2] It has long been settled that where a taxpayer claims to have incurred business losses in connection with some activity, the Court must ascertain objectively whether that activity was carried on by the taxpayer with a reasonable expectation of profit. ...

" [13]     In the case of Nowegijick v The Queen, [1983] C.T.C. 20, at page 25, Dickson J. stated: "...The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...

Source of income, thus, is an equivalent term to business: Dorfman v MNR...See also paragraph 139(1)(ae) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

Beck has been determined not to be an allowable expense and there has been no evidence that any connection with the firm of Felesky Flynn was essential to the appeal process. ...

There was allegedly some borrowing from the appellant's brother, at least in connection with $6,100 which the appellant said was sent in 1995, and no satisfactory evidence of repayment. [15] The most solid piece of evidence that I have is the payment of $7,547 in 1996. ...