Titus v. Canada, 2003 DTC 5158, 2003 FCA 78 (FCA) -- summary under Business Source/Reasonable Expectation of Profit

There was a personal element in the acquisition by the taxpayer of a cottage property close to that of his parents, and the Tax Court judge had properly considered all the evidence, including the fact that interest payments on the mortgage substantially exceeded gross rental revenue, in concluding that the taxpayer did not have a reasonable expectation of profit from the operation of renting the property.