V.A. Miller J. allowed the taxpayer to deduct 50% of approximately $24,000 of business losses incurred in connection with a pyramid sales organization called Advantage Conferences. Evidence demonstrated that the taxpayer had been pursuing the sale of further memberships in a businesslike manner, using a website to promote sales and advertising that website for over $10,000 on Google Adwords. Favreau J. stated (at para. 21):
The absence of a business plan specific to the business activities of the appellant and her spouse is also not determinative because they were following the plan proposed or imposed by the Advantage Conferences to the letter.