Before indicating that there were insufficient details regarding a question on expense deductibility to give a specific response, CRA gave an overview of the tests for expense deductibility, including the identification of a source of income, and stated in this regard:
Where the nature of the taxpayer's business has a personal aspect, the business will only be considered a source of income if it is carried on in a sufficiently commercial manner. In order for an activity to qualify as commercial in nature, the taxpayer must have a subjective intention to make a profit and there must be evidence of a serious business person's conduct supporting that intention.