What is the test to determine whether a taxpayer has a reasonable expectation of profit?

It is worthwhile to examine the quotation from the judgment of Dickson, J. (as he then was) in Moldowan v. The Queen, [1978] 1 S.C.R. at p. 485 where he stated: "There is a vast case literature on what reasonable expectation of profit means and it is by no means entirely consistent. In my view, whether a taxpayer has a reasonable expectation of profit is an objective determination to be made from all of the facts. The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. The list is not intended to be exhaustive. The factors will differ with the nature and extent of the undertaking: The Queen v. Matthews3. One would not expect a farmer who purchased a productive going operation to suffer the same start-up losses as the man who begins a tree farm on raw land."