The appellant submits that in Canadian Marconi v. R., 1986 CanLII 42 (SCC), [1986] 2 S.C.R. 522 (Canadian Marconi), it was recognized that a commercial activity does not require the use of many resources for it to constitute a “business” and that, even if there is no business risk, a commercial activity can still constitute a business if there is a “minimum level of activity.”
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