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Berger v. The Queen 2015 TCC 153 (C. Miller) — business losses for startups — what constitutes a business?

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In this decision, Justice Miller applies the test from the Supreme Court of Canada’s decision in Stewart to conclude that even though this taxpayer incurred losses of $26,540 and $37,866 in 2011 and 2012, with absolutely no revenue in 2011 and only $7500 from a single source in 2012, the taxpayer was carrying on a business and entitled to claim the business losses against other sources of income.  

Mr. Berger was a sports reporter with a radio program for over 20 years when his employer let him go in 2011. He started a blog with the hope of creating enough traffic to attract sponsors to his site. 

Taxpayer’s training

[25]        This is not the case of a hockey fan believing he could be a sportswriter. This is the case of a professional sportswriter believing he could be a businessman.

Capability of venture to show a profit

… It leaves me to guess whether a steady readership in the few thousands is sufficient to attract sponsors to cover expenses of $30,000‑$40,000 a year.

[32]        I conclude the lack of evidence on this aspect, while not helpful to Mr. Berger, is also not fatal.  … As I hope I have made clear to Mr. Berger, my view is limited to the short term start-up phase of his venture.

See Berger v. The Queen 2015 TCC 153 (C. Miller)

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