When his daughter was nine years old, the taxpayer created the "Tennis Mania LP," which used the funds contributed by him to reimburse him for expenses incurred by him in connection with her training and development as a tennis player. Over a 10 year period, the partnership generated no revenues, and the professed objective of receiving a share of her future professional earnings was not binding on her.
Masse DJ found (at para. 22) that the partnership activity was not "being carried out ... in a sufficiently commercial manner so as to constitute a source of income," so that the purported losses allocated to him by the partnership were not deductible in computing his income.