26 March 2015 Internal T.I. 2013-0503031I7 F - Existence d’une source de revenu -- summary under Business Source/Reasonable Expectation of Profit

Although an individual’s activity, which he engaged in in order to generate funds for recreational activities, hade a certain level of commerciality and entailed the monthly tabulation of results by him, they likely did not constitute a business in light inter alia of repeated losses, the absence of intention to increase the scale of his activities, what appeared to be below-market charges by him. As the activity was a hobby allowing the taxpayer to raise money rather than being a source of income, his expenses were non-deductible, and his revenues non-includible, in computing his income.