In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry on a business. Expenses incurred that are “preliminary” rather than “preparatory” are not deductible. See summary by N Menard and S Sandhu Tax Topics no 2732 (June 3, 2025).