Follwell v. The Queen, 2011 DTC [at at 1709], 2011 TCC 422 (Informal Procedure) -- summary under Subsection 5(1)

Hershfield J. found that the taxpayer was not engaged in a business in respect of his work as the assistant rugby coach at Queen's University. As the honorarium was only enough to cover the taxpayer's expenses, there was no reasonable expectation of profit. Hershfield J., considering the control factor in Sagaz, also found that the university had control over the taxpayer, notwithstanding that the control was not exercised and the taxpayer was essentially given a free hand. Employers are able to "dictate the desired result" (such as improving Rugby team performance) to an employee without concerning themselves with implementation details (para. 42).