Indeed, I do not find that in the years at issue the appellant's predominant intention was to make a profit from his rental activities. His principal motive was more to accommodate his son's girlfriend, her friends or relatives and his grandson than to seek a profit. This view is reinforced by the fact that as soon as the girlfriend and her son moved in, and her relatives or friends also moved in, the rental income decreased significantly. As soon as she moved out, the rental income rose. In the years at issue, the appellant's expenses consistently exceeded the rental income. In my view, the venture was not undertaken in a sufficiently commercial manner to be considered a source of income in those years. Such being the case, the appellant is not entitled to claim his rental losses. (See Stewart v. Canada, [2002] SCC 46, paragraphs 50 et seq.)
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