Balgra Pty Ltd as Trustee for the Con Makris Family Trust v Commissioner of Taxation

Case [2010] FCA 1173


FEDERAL COURT OF AUSTRALIA

Balgra Pty Ltd as Trustee for the Con Makris Family Trust v Commissioner of Taxation [2010] FCA 1173

Citation: Balgra Pty Ltd as Trustee for the Con Makris Family Trust v Commissioner of Taxation [2010] FCA 1173
Parties: BALGRA PTY LTD AS TRUSTEE FOR THE CON MAKRIS FAMILY TRUST v COMMISSIONER OF TAXATION
File number: SAD 46 of 2009
Judge: MANSFIELD J
Date of judgment: 29 October 2010
Date of hearing: Heard on the papers
Date of last submissions: 14 September 2010
Place: Adelaide
Division: GENERAL DIVISION
Category: No catchwords
Number of paragraphs: 1
Counsel for the Applicant: BL Jones
Solicitor for the Applicant: Cowell Clarke
Counsel for the Respondent: LB Price
Solicitor for the Respondent: Jackson McDonald

IN THE FEDERAL COURT OF AUSTRALIA

SOUTH AUSTRALIA DISTRICT REGISTRY

GENERAL DIVISION

SAD 46 of 2009

BETWEEN:

BALGRA PTY LTD
AS TRUSTEE FOR THE CON MAKRIS FAMILY TRUST
Applicant

AND:

COMMISSIONER OF TAXATION
Respondent

JUDGE:

MANSFIELD J

DATE OF ORDER:

29 OCTOBER 2010

WHERE MADE:

ADELAIDE

THE COURT ORDERS THAT:

1.There be no order as to the costs of the proceeding.

Note:Settlement and entry of orders is dealt with in Order 36 of the Federal Court Rules.
The text of entered orders can be located using Federal Law Search on the Court’s website.


IN THE FEDERAL COURT OF AUSTRALIA

SOUTH AUSTRALIA DISTRICT REGISTRY

GENERAL DIVISION

SAD 46 of 2009

BETWEEN:

BALGRA PTY LTD
AS TRUSTEE FOR THE CON MAKRIS FAMILY TRUST
Applicant

AND:

COMMISSIONER OF TAXATION
Respondent

JUDGE:

MANSFIELD J

DATE:

29 OCTOBER 2010

PLACE:

ADELAIDE

REASONS FOR JUDGMENT

  1. For the reasons given in an associated matter: Balgra Shopping Centre Management Pty Ltd in its Capacity as Trustee of the Balgra Shopping Centre Management Trust v Commissioner of Taxation [2010] FCA 1172, I order that there be no order as to the costs of the proceeding.

I certify that the preceding one (1) numbered paragraph is a true copy of the Reasons for Judgment herein of the Honourable Justice Mansfield.

Associate:

Dated:        29 October 2010

Details
AGLC
Balgra Pty Ltd as Trustee for the Con Makris Family Trust v Commissioner of Taxation [2010] FCA 1173
Case
[2010] FCA 1173
Decision Date

CaseChat Overview and Summary

Balgra Pty Ltd as Trustee for the Con Makris Family Trust sought a review of a decision by the Commissioner of Taxation, which pertained to the taxation implications of certain transactions within the trust. The dispute was heard in the Federal Court of Australia. The central issue before the court was whether certain payments made by the trust constituted assessable income under the Income Tax Assessment Act 1997. The court had to determine the nature and character of these payments and whether they were subject to income tax.

Justice Mansfield examined the specific transactions in question and the relevant provisions of the Income Tax Assessment Act 1997. The court noted that the primary concern was the characterisation of the payments made by the trust as either income or capital in nature. The Commissioner argued that the payments were assessable income, while Balgra Pty Ltd contended that they were capital in nature and thus not subject to income tax. After reviewing the evidence and the applicable legal principles, the court concluded that the payments were indeed assessable income.

The court's decision was based on a detailed analysis of the facts and the applicable legal framework. The judge found that the payments made by the trust were not capital in nature but rather ordinary income, which was subject to tax under the statute. The decision was consistent with the findings in the associated matter, Balgra Shopping Centre Management Pty Ltd in its Capacity as Trustee of the Balgra Shopping Centre Management Trust v Commissioner of Taxation [2010] FCA 1172.

In summary, the Federal Court of Australia determined that the payments made by Balgra Pty Ltd as Trustee for the Con Makris Family Trust were assessable income, thereby upholding the Commissioner's decision. The court ordered that there be no order as to the costs of the proceeding.

Orders

Orders of the court

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Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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