The taxpayer bought a 10-room inn and lived in it. He started a company ("La Zénon) to operate the inn, which had a restaurant and bar.
Paris J found that inn was not a source of income to the taxpayer, and hence not a source of business losses. The taxpayer charged La Zénon $2000 per month for rent, which was not enough to cover insurance, taxes and maintenance. The taxpayer therefore had no reasonable expectation of profit.