What is the test for reasonable expectation of profit?

Counsel for the appellant stated some factors to be considered in determining whether there was a reasonable expectation of profit. Other factors to be assessed are listed in Sipley v. The Queen, [1995] 2 CTC 2073 (T.C.C.) and reproduced in Tonn, at p. 6013: The objective test includes an examination of profit and loss experience over past years, also an examination of the operational plan and the background to the implementation of the operational plan including a planned course of action. The test further includes an examination of the time spent in the activity as well as the background of the taxpayer and the education and experience of the taxpayer.