Stewart v. R., 98 DTC 1600, [1998] 3 CTC 2662 (TCC) -- summary under Paragraph 18(1)(a)

The taxpayer financed virtually all of the purchase price of four rental units using borrowed money after reviewing offering documents that projected negative cash flow for approximately a 10-year period and a capital gain thereafter. After finding that the taxpayer had no intention to pay down principal, McArthur T.C.J. concluded that the acquisitions had been made without a reasonable expectation of profit.