The appellant appealed reassessments disallowing business losses claimed in the 2013 and 2014 taxation years in relation to abstract photography and string quartet endeavours.
The Tax Court of Canada dismissed the appeal, finding that neither endeavour constituted a source of business income.
The appellant conceded the string quartet endeavour was not a business, and the court found the photography endeavour lacked the necessary hallmarks of commerciality to be considered a business undertaken in pursuit of profit.