The appellant was operating a trade on a commercial basis, but the trade was not being carried on with a view to the realisation of profits, so the appellant was barred from claiming the losses from that trade against her general income. 

The appellant ran a 1,500-acre estate inherited from her father in 2005. The estate generated three income sources: a partridge and pheasant shoot, a biomass boiler, and rental income. The appellant ran the shoot and was shoot captain on shoot days. She was also involved in planning and hosting shoots. The shoot operated around 30 days per season (from September to January). The appellant’s role was to host the shooting days, take bookings, organise catering, take the guns around and control safety. Out of season, the appellant’s role included marketing the shoot and taking the bookings, as well as managing the staff and their day-to-day roles. The appellant employed a head keeper on the estate, but he was