What is the difference between a Minister's determination that a taxpayer has a reasonable expectation of profit?

In the case of The Queen v. Andrew Donnelly, supra, it is made clear that there is a distinction between the test to be applied when determining whether farming is a taxpayer's chief source of income and the test to be applied when determining whether or not there is a reasonable expectation of profit. On the basis of the reasoning of Robertson, J.A., one can see the rationale of the Minister in conceding that there may have been a reasonable expectation of profit and yet concluding that farming was not the chief source of income for the Appellant. As Roberston, J.A., pointed out: "... the legal test for establishing farming as a chief source of income is, on an evidential level, a more onerous one."