In 2011, the taxpayer lost his job at a radio station as a sports broadcaster. He started blogging on the Maple Leafs with a view to generating revenues from advertisers, and used his severance package to cover expenses (amounting to $37,000 in 2012) including paying a consulting firm to design a professional website and travel expenses associated with following the team for their away games. During the period under review (being the first 18 months of the blog/website), there was only one sponsor, who paid $7,500.
C Miller J found that there was a personal element to the activities of the taxpayer, who was a sports fan, also stating (at para. 20) that "'blogging' is by its nature as much a recreational pastime as possibly a commercial practice."
However, notwithstanding that the taxpayer had not actively pursued finding sponsors an focused on his website's content, C Miller J allowed the taxpayer's losses as business losses given that the period under review was the start-up phase, this activity was an extension of his previous experience, and his course of conduct was "not so devoid of commercial reasoning to conclude the venture was personal and nothing more" (para. 30).