The appellant appealed reassessments disallowing business expense deductions for his wholesale luxury auto operation in the 2016 and 2017 taxation years.
The Minister argued the activity was a personal endeavour without a reasonable expectation of profit.
The Tax Court found that despite some personal elements, the activity was carried out in a sufficiently commercial manner to constitute a business source of income.
The appeal was allowed, permitting the deduction of conceded and certain other expenses, and allowing the carry-back of resulting non-capital losses to 2014.