Before going on to find that rental losses incurred by the taxpayers were fully deductible by them, Linden J.A. stated (at p. 6005) that s. 18(1)(a) required that an:
expense must have been incurred within a business framework, bearing some relation to the income earning process ... . [S]uch intention, strictly speaking, is subjective; no requirement of objective reasonability is expressly imposed by the section.