Regarding whether a taxpayer deriving income from placing sports bets had a source of income, CRA stated:
[A]n activity that does not have a reasonable expectation of profit cannot be a source of income. Where there is no expectation of profit, neither amounts received nor expenses incurred are to be included in computing income and any excess of expenses over revenues is a personal or living expense, whose deduction is not permitted under paragraph 18(1)(h). However, if the hobby results in more revenue than expenses, this is a clear indication that the pastime is a business carried on with the expectation of profit.
... [T]he fact that your client has earned more than $20,000 as of October 2009 … [indicates] that there is a source of income … .