Coles Meyer Finance Limited v The Commissioner of Taxation of the Commonwealth of Australia

Case

[1992] HCATrans 131

No judgment structure available for this case.

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IN THE HIGH COURT OF AUSTRALIA

Office of the Registry

Melbourne No M33 of 1991

B e t w e e n -

COLES MYER FINANCE LIMITED

Appellant

and

THE COMMISSIONER OF TAXATION OF

THE COMMONWEALTH OF AUSTRALIA

Respondent

MASON CJ
BRENNAN J
DEANE J

DAWSON J

TOOHEY J

GAUDRON J

MCHUGH J

Coles(2) 1 5/5/92

TRANSCRIPT OF PROCEEDINGS

AT CANBERRA ON TUESDAY, 5 MAY 1992. AT 10.18 AM

Copyright in the High Court of Australia

MR F.H. CALLAWAY, OC: If it please the Court, I appear with

my learned friend, MR G.T. PAGONE, for the

appellant. (instructed by Freehill Hollingdale &

Page)

MR J.M. BATT, QC:  May it please the Court, I appear with my

learned friend, MR C.M. MAXWELL, for the

respondent. (instructed by the Australian

Government Solicitor).

MASON CJ:  Mr Callaway?

MR CALLAWAY: If the Court pleases. Your Honours, in this

matter written submissions have been filed and

exchanged so there is no three page outline, but I

thought it might, nevertheless, be helpful to the

Court if I indicated the shape of this morning's

submissions. I propose to ask the Court to go

first to the special case, not for the purpose of

reading it but just to identify some of the

critical facts on which the matter turns, and then,

I hope this is not too ambitious, to try to put our

argument in a nutshell, and only after then to go

to those paragraphs of the written submission that

might require some amplification but, hopefully, at

the end of the nutshell the principal issues

between the parties will have been laid out.

The special case is at the beginning of the

appeal book, starting at page 2, sets out the

questions with which Your Honours are familiar from

reading the judgments of the court below, the

history of the appellant and the nature of its

business, and at paragraphs 3 and 4 annexes

representative bills of exchange and representative

promissory notes.

We have prepared a little chart which simply

summarizes the representative bills and notes

showing who the acceptor was, who the payee was,

what the respective periods were, and the like. If

that might be of assistance to Your Honours,

perhaps I might hand the chart up. It was a chart

that was made available to the court below.

We also have in Court, but we do not press on

Your Honours, the original bills of exchange and

promissory notes. In some ways they are more

informative because they are much easier to read

than the photocopies in the appeal book. We have

them here if the Court desires to see them. For

present purposes, it may be sufficient just to go

to one of the bills and one of the notes.

If Your Honours turn to annexure 3B at

page 21, one sees an example of a bill drawn on the

Coles(2) 2 5/5/92
ANZ Bank. Down the bottom right-hand corner, one

sees that the drawer is the appellant. Next to

that, one sees that it is drawn on the ANZ Bank, and in this case if one looks a little higher up

the page, it is "Pay to order of" the ANZ, so in

the case of this bill, the drawee was also the

payee.

That was also true of the bills drawn on the National Bank. In the case of the Commonwealth,

the payee was the appellant. Then to the left, one
sees the acceptance. On the back of the bill,

which of course is page 22 of the appeal book, one

sees the successive endorsements beginning with the

endorsement of the original payee, the ANZ Bank.

For an example of the notes, if one goes

really to either of them, but annexure 4A, page 34,

a much simpler document, the appellant:

promises to pay to the bearer the sum of One

Hundred Thousand Dollars ($100,000) on the

TWELFTH day of OCTOBER 1984 fixed -

the significance of the word "fixed" of course is

to exclude the days of grace -

upon presentation and surrender of this note.

Then down the bottom left-hand corner, it is payable at the National Bank, but that is not in

the body of the note. On the back there is simply

a provision to acknowledge surrender and payment.

The second note is in the same form, and the

surrender provision on the back is somewhat more

legible.

The special case, then, back at page 4, in

paragraph 5, records that:

The relevant bills and relevant notes were in
a usual or common form. The relevant bills
were drawn in June 1984 -

that is to say, in the year of income -

and the number of days between their drawing
and maturity ranged from 98 to 183 -

That, in fact, is not right, because if one looks at annexure 3A the period is 69 days, but nothing

turns on that.

The relevant notes were made between January

and April -

in the year of income -

Coles(2) 5/5/92

and the number of days between their making
and maturity ranged from 181 to 183.

Then the special case sets out the face value of the bills and notes and the amount received when they were discounted, giving rise to the amounts of

$2,375,579 and $2,359,893, which are the deduction

claimed. The following paragraphs set out the

history of the return and assessment, objection,

disallowance and, at paragraph 11, records that:

The relevant bills were accommodation bills

accepted by one or other of -

the three banks "for the accommodation of the",

now, appellant. Paragraph 12 sets out what
happened in relation to raising finance by means of

bills. Paragraph 13 sets out what happened in the

case of the notes. Staying for a moment with

paragraph 12, it is unnecessary to read paragraphs (a) and (b). Paragraph (c):

The applicant typed the bills on a printed

form provided by the accepting bank, signed

the bills and presented them to the accepting

bank for acceptance. Upon acceptance the

bills were returned to the applicant's offices

where a representative of the successful

tenderer or tenderers (which may have been or

included the accepting bank) was handed the

bills in exchange for a cheque for the purpose

price.

And it may be inferred that the payee had endorsed

them for that transaction to make sense and one

sees that endorsement in the representative notes.

Paragraph (d) - it does not matter that there

is a typographical error - is:

In the case of the representative bills

referred to in paragraph 3 the successful

tenderers were Westpac Banking Corporation in

respect of annexure "3A", Spedley Securities

Limited in respect of annexure "3B" -

that it is transposed. In fact, it is Spedley in

respect of A and Westpac in respect of B.

All of that occurred on the same day, so that

the bills were drawn, accepted and discounted on

the same day. The bank charged an acceptance fee,

but that is not in issue:

The purchaser or purchasers of the bills

commonly sold them at some time prior to their

Coles(2) 4 5/5/92

maturity date. In many cases a bill was sold

several times before that date -

and, of course, that is normal practice in the bill

market.

Because they will be relevant to the argument,

I should read the next few paragraphs:

(h) There was no legal impediment to the

applicant repurchasing the bills in the market before their maturity date, but in fact it has

never repurchased any bills drawn by it -

not just the relevant bills the subject of this
appeal, but any bills:

The applicant has at all times participated in the market not as an investor but solely to obtain funds.

(i)       On the maturity date the then holder or

any of the relevant bills, the accepting bank -

holders of the bills presented them to the the case of

accepting bank for payment and they were paid.

so that - and this will material later - the

accepting bank sometimes was the successful
tenderer and the first holder for value of the

bill, but the accepting bank was never the holder

on the date of maturity. If the accepting bank had

been the holder on the date of maturity the bill

would have been discharged pursuant to section 66

of the Bills of Exchange Act, but as we will see

later, the appellant would still have had to pay

the face value to the bank as the holder.

(j) All three accepting banks debited the

applicant's account on the maturity date with

an amount equal to the face value of the bills
maturing on that day. ANZ did so shortly

after they were presented and paid. NAB and CBA did so shortly after the commencement of business on that day and usually before they were presented or paid.

The relevance of that, of course, is that the court

below said that there was no liability incurred

until the accepting bank had paid the third party

holder. In fact, only one bank followed that

practice. The other two banks commonly put

themselves in funds before paying the holder which,

indeed, is the appropriate course with an

accommodation bill.

Coles(2) 5 5/5/92

(k) sets out the letters and the like that lay

behind these arrangements but it is common ground,

I think, that nothing turns upon those letters.

This was a simple bill discounting arrangement, not

a bill discounting arrangement governed by a

facility agreement that impinged on the general

law.

In the case of the notes, similarly, 13(c):

The appellant typed the notes on a form

printed by the applicant and signed them. A

representative of the successful tenderer or

tenderers was handed the notes in exchange for

a cheque for the purchase price.

That all occurred on the same day, too.

(e) The purchaser or purchasers of the notes

commonly sold them at some time prior to their

maturity date.

(f) There was no legal impediment to the
applicant repurchasing the notes in the market

before their maturity date. The applicant has

at all times participated in the market not as

an investor but solely to obtain funds. It

has repurchased notes on only four occasions

since its incorporation.

But those are all after the year of income.

(g) The applicant did not repurchase any of

the relevant notes or any other notes during
the year of income or during the -

following year, the 1985 year of income. And then,

on the maturity date the notes were presented for

payment.

Paragraph 14 deals with any concern there

might have been that the bills or notes might not

have been presented on the maturity date:

It is extremely rare for a bank accepted bill not to be presented for payment. In the case of NAB, which in the course of a year accepts

many thousands of bills to a total amount in

billions of dollars, every bank accepted bill since at least 1981 has been presented on its maturity date or in a very few cases shortly

thereafter and then have all been paid. Where

a bill has been lost or destroyed arrangements

have been made to pay the former holder its

face value upon receiving a suitable

indemnity. The experience of NAB is similar
Coles(2) 6 5/5/92

to that of all other Australian banks

operating in the bill market, including -

the two other banks with which this case is

concerned.

In the experience of -

those three banks -

it is also extremely rare for a promissory
note not to be presented and paid on its

maturity date and, in the isolated cases where

late presentment has occurred, it has been

within a few days of that date and the note

has then been paid. All the relevant bills

and relevant notes ere presented and paid on

their maturity dates.

The special case then turns to the alternative

submissions of the parties, because the primary

submission of the appellant is that the liability
on the promissory notes was incurred on the day
they were discounted, and the liability on the
bills to the accepting bank was incurred on the day
they were discounted, and the Commissioner's case

is that in both cases one waits till the day of

maturity. The middle ground - - -
BRENNAN J:  I thought the day of acceptance was on the day

of discounting?

MR CALLAWAY:  On the day of discounting, Your Honour,

because if one takes this sequentially, if I am the

drawer first I draw a bill, there is no pecuniary

liability. I give it to the bank to accept, and at

that stage there is still no pecuniary liability,

there will be nothing that has to be paid. But

once it is discounted for value then, of course,

there is someone who will be entitled to payment on

the day of maturity.

BRENNAN J: Yes.

MR CALLAWAY:  The middle ground is that one should spread

the allowable deduction over the life of the bill

or note. In the case of the appellant that is a

subsidiary, alternative submission if we are wrong

about the primary submission, but it was all

incurred in the 1984 year of income. In the case

of my learned friends it is an alternative
submission if they are wrong, that one waits for
the 1985 year of income before the relevant
liabilities are incurred. It is not necessary to
read these paragraphs at any length, they set out
the accounting practice. The accounting practice

is to spread the discount over the life of the

Coles(2) 7 5/5/92

bill, and that is set out in detail in

paragraphs 15, 16, 17 and 18 of the special case.

At the time the special case was drafted the

relevant companies legislation was the Companies

Act 1981 and the corresponding State Codes, but our instructions are that there are still no applicable accounting standards within the meaning of the

corporations law and its associated legislation, so

that the reference to the Companies Act 1981 in

paras 15(a) and 16(a) need not cause the Court any

concern.

This case as regards bills is, of course,

about the liability of the party accommodated to
the accepting bank as the accommodation party.
There is, I think, no controversy that the bank as
acceptor has a present liability from the

beginning, from the time the bill is first

discounted. So the bank is the party primarily

liable on the bill as acceptor.

One finds that reflected in the accounting

practice under which the bank's liability as

acceptor to the holder of the bill is recognized as

a liability of the bank from the day on which the

bill is drawn, accepted and discounted. There is

an illustration of that in the appeal book in the
balance sheet of the National Bank at page 137.

In annexure 17A, line 26, one sees in the

bank's liabilities, Liability on acceptances,
$4 million-odd. That is the bank's liability as

acceptor. On the next page, one finds the

corresponding item in the assets, line 23, "Due

from customers on acceptances", the same amount.

That is the bank's right to turn to the party

accommodated for its indemnity.

If the Court ultimately decides that the

accounting practice is relevant and apportionment

is the appropriate course, paragraph 19 records

that the appellant followed that accounting

practice in relation to the relevant bills and the

relevant notes.

Your Honours, let me turn to the more

difficult part of the three-section assignment I

gave myself 20 minutes ago, and try to put the case

in a nutshell, putting to one side the

apportionment-spreading alterative submission.

First as regards the notes, if one goes to the

Bills of Exchange Act, one finds in section 89(1)

that:

A promissory note is an unconditional promise

in writing -

Coles(2) 5/5/92

an unconditional promise in writing -

made by one person to another, signed by the

maker, engaging to pay, on demand or at a

fixed or determinable future time, a sum

certain in money, to or to the order of a

specified person, or to bearer.

And in section 94(a), that:

The maker of a promissory note, by making it:

(a) engages that he will pay it according to

its tenor -

and, if it matters, section 93(1) provides, so far as these notes are relevant - are concerned - that

presentment for payment is not necessary in order

to render the maker liable, because the place of

payment is not in the body of the note, it is an

annotation in the left-hand corner and that is what
the authorities say.

In our respectful submission, if, as the Bills

of Exchange Act says, the promissory notes are
unconditional promises in writing, they must be

presently existing liabilities.

TOOHEY J:  To whom?
MR CALLAWAY:  To the bearer of the notes, Your Honour,

because of course we do not have to worry about the

accepting bank, but the promissory notes, and

therefore incurred for the purposes of section 51.

We would submit they are a clear example of a

presently existing liability of an obligation that

is fully incurred, even though it is to be paid at

some future time, and clearly distinguishable from

Nilsen's case.

BRENNAN J:

Is it an implication of your argument that the

discounted price should be brought to account as

revenue in one year and the discharge price brought

to account as an outgoing in the next?

MR CALLAWAY:  No, Your Honour. Our submission is the loss

which is known from the beginning should be brought

to account as an allowable deduction in the first

year of income.

BRENNAN J:  So your argument turns upon the fact that a loss

is known to be incurred from the beginning?

MR CALLAWAY:  Yes, Your Honour.

BRENNAN J: What would happen if a bill was repurchased on

1 July by the drawer?

Coles(2) 5/5/92
MR CALLAWAY:  Your Honour, that is an event of defeasance

within the meaning of authorities like Commonwealth

Aluminium and an event of defeasance which the

special case shows was remote at the time the note

was made and which, in the event, did not happen,

so that again, in accordance with Commonwealth

Aluminium and Willis v Commonwealth, referred to by

Mr Justice Newton in that case, one is entitled to

disregard the remote possibility which, in fact,
did not happen. That, indeed, would have prevented

the note having to be paid in the next year of

income, if it had been repurchased and held at any

time.

BRENNAN J: What would be the tax implications?

MR CALLAWAY:  There would have to be an adjustment in that

case, Your Honour, and the amount that was
successfully claimed as an allowable deduction in

the first year of income would have to be brought

to account as assessable income in the second. It

may not be quite as simple as that, not in relation

to promissory notes, but the matter of adjustments

and the authorities are referred to by

Mr Justice Newton in Commonwealth Aluminium at

page 4161, left-hand column, point 5. I do not
promise I can always do that.

In Nilsen, if the Court pleases, the case that

was concerned about annual leave and long service

leave, there simply was no pecuniary liability
until the employee actually entered on the period

of leave. That, with respect, is what Nilsen's

case is all about whereas in the case of the

promissory notes there is a pecuniary liability
from the beginning. A promissory note is, "I

promise to pay". Nilsen's case is, "I am under an

obligation to allow you leave. When you take it,

of course, I'll have to pay you", but the

obligation is actually to allow the leave.
DAWSON J:  Why is not the obligation to pay when the day

arrives?

MR CALLAWAY:  Your Honour, that, with respect, is a general

formula that would cover both, but in the case of

the promissory note, the obligation is at all times

pecuniary from the beginning to the end. In the

case of leave, the obligation is to allow the

leave. It has no pecuniary aspect at all until the

employee actually enters on to the leave and then,
of course, has to be paid.

Later on I propose to take the Court to the

High Court's decision in Nilsen but it is, in our

submission, instructive to begin with what was said

in the Full Court of the Federal Court and it is

Coles(2) 10 5/5/92

also, I think, a further answer to Your Honour

Justice Dawson's question.

Nilsen's case in the Full Court of the Federal

Court is number 10 on our list of authorities and

the majority consisted of Your Honours

Justices Brennan and Deane, and in both

Your Honours' judgments the distinction on which we

rely appears and it similarly underlies the

decision of this Court affirming the court below.

For example, in the judgment of Your Honour

Justice Brennan at page 242, line 39:

At the end of the year, the entitlement of the

relevant employees was not a present

entitlement to money. Reciprocally, the

respondent's obligation was not then a

liability to pay money.

And three lines from the bottom:

no pecuniary liability was imposed during the

income year.

Then, on page 244, line 13:

At the end of the income year, none of these employees had an entitlement to be paid money.

The respondent's pecuniary liability to any

employee would not arise until the time

specified in sub-cl (j), that is "before going

on leave", or the time specified in

sub-cl (1), that is, when the employee "leaves

the employment of the employer or his

employment is terminated", whichever first

occurred.

Then, a few lines later, around about line 26:

In respect of neither kind of deduction

can it be said that the respondent was under a

present pecuniary liability at 30 June 1974.

None of the amounts provided by the respondent

in its 1974 accounts represent a debitum in

praesenti, solvendum in futuro: there was no

present pecuniary liability.

But, Your Honours, that is, of course, exactly what

a promissory note is, a debitum in praesenti,

solvendum in futuro and, Your Honour, distinguishes

the non-pecuniary liability in Nilsen from such a

debitum in praesenti. Your Honour goes on to say:

This is not a case of an award which entitles

the employer to defer payment of moneys due to

a workman.

Coles(2) 11 5/5/92

That, of course - Your Honour's hypothetical

example - would be an example of a pecuniary

liability incurred now, presently existing

obligation, though not to be paid until the future;

owing now, payable later, like the deferred

interest in the debentures Your Honour

Justice Toohey considered in AGC: present obligation though payable at a future time,

incurred once it is a present obligation.

TOOHEY J:  Mr Callaway, you said in respect of the

promissory note that there was a liability from the

beginning. What do you mean by that? Do you mean
at the moment of execution or when someone came in

possession of the note or what?

MR CALLAWAY: As soon as it is discounted, Your Honour.

TOOHEY J: But it does mean at the moment of execution?

MR CALLAWAY:  No, Your Honour, it is a bit like the answer

to His Honour's about the bills: once I sign the

promissory note that does nothing but when I

deliver it for value to the successful tenderer

that is when the present obligation accrues.

TOOHEY J: And that is what we are to understand by the

expression "from the beginning"?

MR CALLAWAY:  Yes, Your Honour, my fault for not putting it

clearly from the beginning. Yes, Your Honour,

from the day of discounting, because there is then

a holder for value. And, similarly, with the

bills of exchange.

Your Honour Justice Deane, at page 248,

line 31, said:

The primary entitlement of a continuing

employee in respect of long service leave and

annual leave is an entitlement, during a

period of employment in respect of which he

will be entitled to the payment of salary or

wages (sometimes with a loading), to be

excuse the employee from work and from

excused from working or attending for work.

attendance at work while paying the employee's

salary or wages, together with any loading, in

respect of the period of leave.

So, again, the obligation is actually to allow

the leave. There is no pecuniary obligation until

the leave is entered upon. On the next page, at

line 36, in a passage which Your Honour the

Chief Justice later quoted and endorsed in this

Court, Your Honour said:

Coles(2) 12 5/5/92

at the heart of the joint judgment in the

James Flood case, supra, lies a recognition of

the competing concepts of the nature of the

liability to make payments in respect of

annual leave, namely, the commercial view of

that liability as a progressive one which

should be treated as part of the cost of

labour employed from day to day and the

jurisprudential view that the liability

remains the ordinary liability to pay wages to

an employee in respect of a period of

employment notwithstanding that the employee's

entitlement to leave excuses him from working

or attending for work during the period.

Your Honour then says that the latter is the

correct legal view. And I might just add, as a

footnote, that that is the way in which Nilsen's

case in both courts has been understood, and its

ratio is described in similar terms by

Mr Justice Hill in Ogilvy & Mather. I do not wish

to read that passage to the Court, it is referred

to in our written submissions at paragraph 22. In

Nilsen's case the taxpayer's obligation was an obligation to allow leave to employees and, until

the period of leave was entered upon by an

employee, there was no pecuniary obligation either

due or payable and that is a summary of what

Mr Justice Hill said was his understanding of

Nilsen in Ogilvy & Mather at page 4862.

Your Honours, the importance of this lies in a

passage in the judgment under appeal at page 184 of

the appeal book. In the part of the judgment
dealing with promissory notes, Their Honours drew
support from Nilsen. Reading from line 14,

Their Honours say:

It will be recalled that, in Nilsen, the

employees had already become entitled to take

their long service leave. So the taxpayer,
within the relevant tax year, was in the

position that it was bound to pay the value of

that leave on demand.

As we have seen that is, with respect, a

misapprehension of the basis of the decision in

Nilsen's case. Then, omitting the next sentence: In the present case, in the relevant year of income, the applicant certainly incurred a

legal obligation to pay the value of the

promissory notes.

With respect, that is so, incurred a present pecuniary obligation, unlike Nilsen's case.

Coles(2) 13 5/5/92

Your Honours, it must, in our respectful

submission, be significant that neither in the Full

Court of the Federal Court, nor in the written
submissions in this Court, have the very

experienced counsel for the Commissioner propounded

any reason of principle why the liability on the

promissory notes would not be incurred at the time

of discounting. The only argument that has ever

been advanced by the Commissioner is that, in the

Nevill's case, this Court decided that the

liability on promissory notes was incurred in the
year in which they were paid, not the year in which

they were made.

I will be saying more about Nevill's case

necessarily later in the argument, but bearing in

mind that this is the nutshell section of the

argument, might I content myself with just

referring Your Honours to what we say in the notice

of appeal about Nevill's case at page 195. That

really sets out our submission in brief form. In

paragraph 17, our first submission is that Nevill,

to the extent it dealt with the timing issue on

promissory notes - it deals with other matters

which we do not need to address - was wrong in

principle but it was not a binding authority.

Speaking very generally, it was not a binding

authority, in our submission, because the

Chief Justice expressly said that he was not

deciding the question; Mr Justice Rich expressly
said that he was not deciding the question. In our
submission, on a fair reading nf

Mr Justice McTiernan's judgmenc, His Honour was

agreeing with the Chief Justice. So that only one

member of the Court, Mr Justice Dixon, decided the

question in a sense that would be binding even on a

court below this Court.

But if we are wrong about that, our second submission about Nevill is that it was

authoritatively explained by this Court in Flood at

the reference given in the notice of appeal and, as

so explained, does not apply to these promissory

notes. It is only really if we are wrong on both

those points that we come to the point of asking

for leave to argue that it should be overruled on

the timing point. So that essentially on the

notes, we submit they are a clear example of a

presently existing liability that is incurred, and

there is no reason in principle why that should not

be so, and that Nevill's case is not a bar to that

conclusion.

The bills of exchange are more complicated,

but the essential issue between the parties is

whether the liability of the party accommodated,

Coles(2) 14 5/5/92

the appellant, to indemnify the accepting bank is a

presently existing liability or just a contingent

liability which is not a presently existing

liability until, for some reason, the day of

maturity.

In response to that, we advance five

submissions. The first is that it appears from the

judgments in K.D. Morris that the liability of the party accommodated to indemnify the accepting bank

is a presently existing liability from the time of

discounting. In a moment I will ask the Court to

go to K.D. Morris, but it might be convenient,

Your Honours, if I say what the five submissions

are rather than get them separated by long parts of

transcript.

Secondly, the test of whether a liability is

incurred is not whether the other party has a cause

of action. So that it is not to the point to refer

to cases which say that a surety has no cause of

action against a principal debtor until the surety

pays the debt. The test is not cause of action.

If it were, of course, a liability would never be
incurred for the purposes of section 51 until it

was payable. ·
DAWSON J:  The bills were presented to the bank rather than

to the appellant for payment, were they not?

MR CALLAWAY: That is so, Your Honour, yes, because the bank

is the acceptor, so that the holder will necessary

go to the acceptor on the day of maturity - - -

DAWSON J: Although he also indemnifies the drawer of the

bill.

MR CALLAWAY:  With respect, no, Your Honour. On the day of

maturity, the holder goes to the bank as the
acceptor because on the face of the instrument the

party primarily liable is, of course, the acceptor.

The acceptor, because it is an accommodation bill,

is entitled to be indemnified by the appellant.

DAWSON J:  I see.
MR CALLAWAY:  It is that liability of the appellant to

indemnify the bank which is what this branch of the

case is all about. We submit that that is a

present liability from the time of discounting,

though to be performed in the future, but a

presently existing liability and my learned friends

say, "No, it's not a presently existing liability.

It isn't incurred until the day of maturity". A

major plank of my learned friend's argument is to

say the accepting bank is, in the case of an

Coles(2) 15 5/5/92

accommodation bill, a surety for the party
accommodated which is true as far as it goes.

DAWSON J: Could the bill be presented to the drawer for

payment?

MR CALLAWAY:  It could, Your Honour, and if it were paid by

the drawer it would, in fact, discharge the bill
because there is a provision in the Bills of

Exchange Act which says, exceptionally, that where an accommodation bill is paid by the party

accommodated, the bill is discharged.

DAWSON J:  So that there is a liability in respect of the

drawer, also from the moment of -

MR CALLAWAY: 

Yes, Your Honour, because it is an accommodation bill.

DAWSON J: But if the acceptor pays, then the acceptor is

entitled to be indemnified by the drawer?

MR CALLAWAY:  Yes, Your Honour. So, the second submission

is that the test is not when the bank has a cause
of action.

The third submission is that the test is not whether there is a debt, and really that is our

respectful answer to paragraphs 10 to 12 of my

learned friend's written submission. I will say

more about it in a moment but that is what it is

relevant to.

DAWSON J:  If I can just come back, Mr Callaway. Why do you

concentrate on the liability to the bank and not the liability as drawer? I mean, that is in the events as they happened, but the drawer is liable

one way or another.

MR CALLAWAY:  Yes, Your Honour. If one has an ordinary bill
of exchange, not an accommodation bill, of course,

the hierarchy of liability is the acceptor is

primarily liable and if the acceptor does not pay,

the holder can turn to the drawer. If the drawer

does not pay, one can go successively down the
endorsers. That liability of the drawer, we would

not be able to rely on because that is a contingent

liability. That is a liability to pay if the

acceptor defaults.

Because it is an accommodation bill, although

the bank on the face of the instrument is the party
primarily liable, the bank is entitled to be
indemnified by the drawer. That obligation, as

between the appellant and the bank, is the

obligation on which we rely. That is the

obligation, we say, is the presently existing

Coles(2) 16 5/5/92

obligation and it can only arise because of the

accommodation bill.

The fourth submission is this, that true it is that with an accommodation bill the accepting bank

is a surety for the party accommodated and that is,

of course, what leads my learned friends to make

their submission that in such a case the liability

must be contingent and why my learned friends do

not say this in the written submission, no doubt

what lies behind them is the thought that in an
ordinary principal surety situation, the liability
of the principal debtor to indemnify the surety
would be contingent because the liability of the

surety, the guarantor, is contingent, and the

liability to indemnify the guarantor must be

contingent.

But in the ordinary principle and surety situation it is very different.

"I guarantee the

debt of X" means, "I will pay if X does not". Of
course that is contingent. "And X's obligation to

indemnify me if I have to honour the guarantee"

must be contingent too. But the relationship on an accommodation bill is quite different. The promise by the accommodated party, the appellant, where

there bill is in the hands of a third party, as all
these bills ultimately were, is to indemnify the

bank when the day of maturity arrives. There is no

question of, "I will pay if in default and

unexpectedly, you do not pay". It is, "I will pay

willy-nilly, on the day of maturity because the

bill is accepted for my accommodation". I will say
a bit more about that in a moment.

The fifth of the five submissions which is not

reflected in our written submissions which I

apologize, the full significance of which, if it is

significant, has only dawned on us in the last few

days, is that the best way of describing the

contracts between the party accommodated and an

accommodation party, is that the party accommodated

will, as between them,be regarded as the real

acceptor of the bill, and there is authority for

that that I will take the Court to in due course.

So that, as between the appellant and the bank, the contract of accommodation is that the appellant

will be regarded as the real acceptor of the bill.

Everything, in our respectful submission, flows from that. If the bill is in the hands of a

third party on the day of maturity, the

understanding that the appellants will be the real

acceptor of the bill is what gives rise to the

obligation to indemnify the bank. If the bill were

held by the bank at maturity, it would be

Coles(2) 17 5/5/92

discharged because section 66 provides that where a

bill is held by the acceptor at maturity, it is

discharged. But obviously the bank, having given

value for the bill, would still be entitled to be

paid the face value by the appellant, because the
bargain, as between them, is that the appellant
will be regarded as the real acceptor. If the

appellant were the acceptor the holder would be

entitled to go and be paid and the bill would not

be discharged because it would not be - the

acceptor and the holder would not be the same

person.

It is still appropriate to talk about an

obligation to indemnify, but the obligation there

is to indemnify the bank against the consequence of

accepting that the bill has been discharged. So

that the critical thing is that, as between the
bank and the appellant, the agreement is that the
appellant will be regarded as the real acceptor of

the bill.

DAWSON J:  And it is true to say that if an accommodation

bill were presented for payment to the drawer and

the drawer paid, the bill would be discharged?

MR CALLAWAY: That is so, Your Honours, yes.

DAWSON J: Unlike the case of a non-accommodation bill, in

which case there would still be recourse to the

acceptor.

MR CALLAWAY:  Yes, Your Honour. Would Your Honours pardon

me a moment, I will see if I can find the section

quickly; otherwise we will find it over lunch. I

am very grateful to my learned friend who says

that it is section 64(3):

Where an accommodation bill is paid in due

course by the party accommodated, the bill is

discharged.

If I could just develop those five submissions, beginning with K.D. Morris, which is No 6 on our

list of authorities. Your Honours will recall that

that case concerned a bill facility under which a

company raised finance by discounting bills of

exchange, went into liquidation and the liquidators

continued to roll over the bills. The critical

issue in the case was whether the amounts raised by

the liquidators could be regarded as costs and

expenses of the winding up with the attendant

priority.

That, in turn, depended on the view one took

of the bill transactions. One view was that by

reason of the facility agreement, an elaborate

Coles(2) 18 5/5/92

facility agreement, there was but one continuous

transaction. Even when the liquidators raised

money by rolling over the bills, that was just a

continuance of a transaction that had begun before

the liquidation. The other view was that each time

the bills were rolled over there was a fresh

raising of finance by the discounting of bills.

Mr Justice Murphy decided the case on a basis

which did not touch on that distinction. The other
members of the Court were evenly divided:

Mr Justice Stephen and Mr Justice Wilson held that

there was but one continuous transaction going back

before the date of winding up and, accordingly, the

moneys raised by the liquidators after winding up

were not costs and expenses of the winding up.

Your Honour the Chief Justice and Mr Justice Aickin

held that each time the bills were rolled over

there was a discrete transaction and the moneys

raised by roll over after winding up could be

regarded as costs and expenses of the winding up.

It is not necessary - unless the Court wishes

me to do so - to read the headnote and I would

simply mention to Your Honours that the headnote, as we understand it, is wrong. In the sixth last

line on page 165, the writer of the headnote says:

As a result of the arrangement, the company

was contingently liable to the bank for

$1,000,000.00 when the term of the facility

should end.

One issue on which the four members of the Court

who had dealt with this issue were unanimous was
that it was not a contingent liability. That must

come just from a misreading of the judgment.

Mr Justice Stephen and Mr Justice Wilson make it

clear they do not regard it as a contingent

liability, at page 174. Your Honour

His Honour made it clear that it was not a the Chief Justice agreed with Mr Justice Aickin and contingent liability passim throughout the judgment
but, particularly, perhaps, at pages 193, 200 and
202.

For present purposes, it is sufficient to ask the Court to go first to page 175 in the joint

judgment of Mr Justice Stephen and
Mr Justice Wilson. On the opposite page, 174,
Their Honours had been analysing the position in
terms of the facility agreements. Now, of course,
we cannot rely on that because here there was no
relevant facility agreements. It is common ground
that the letters left the common law position in
tact. But, at page 175, Their Honours dealt with
Coles(2) 19 5/5/92

what the position would have been without a

governing facility agreement:

Had the Bank been only a casual acceptor of the Company's bills, bound by no agreement

to accept them and only doing so in each case

as an isolated transaction, there would be no

continuing liability. Instead there would be

a series of unconnected relationships whereby

the Bank became surety for the Company for

particular accommodation bills and the Company

assumed a liability to the Bank accordingly - we submit that that means assumed the liability at

the time of discounting -

which liability would be discharged when the

Company put the Bank in funds to retire the

bills on maturity.

A present obligation to be discharge in the future.

The acceptance of each new bill would give

rise to a fresh liability.

The context makes it clear that that means a fresh

liability on the part of the company.

DAWSON J: But it would occur on acceptance.

MR CALLAWAY:  Yes, Your Honour, the acceptance of each bill

would give rise to a fresh liability on the part of

the company. That is the liability in effect to

indemnify the bank.

DAWSON J: But you say the liability arises on discounting.

MR CALLAWAY: That is true, Your Honour. These of course

were roll-overs, so it is accepted and discounted

probably almost on the same day. With respect, it

cannot be that Their Honours are saying that it

arises simply on the acceptance.

Your Honour the Chief Justice concurred with

Mr Justice Aickin at page 179, and the two critical

passages - although I will mention a third for a

reason that will become relevant later - in
Mr Justice Aickin's judgment, the first is at

page 200, point 6 of the page, the beginning of the

first full paragraph:

The liability to indemnify the Bank was

not contingent except in the sense that, if a

bill were not presented, there would be no

occasion for indemnification.

In tax terms, there would be a defeasance.

Coles(2) 20 5/5/92

Once the bills were presented the Bank was

obliged to discharge its liability to the

holders, and the obligation on the Company to

indemnify it arose, unless it had been

discharged by the provision of the full face

value to the Bank in advance.

If I can then go to the other two passages and

come back to the third one. On page 202, about

point 4 of the page - it is a line beginning with

the word "agreement" - His Honour then says:

The liability of the Company was not dependent

upon any contingency once the bills had been

discounted.

That, with respect, is our case on this branch.

On the Bank paying each bill on presentation,

the liability to indemnify arose by reason of

the inherent characteristics of an

accommodation bill. The liability of the

Company under the agreement was to provide

funds to the Bank in advance of the maturity

date by discounting replacement bills but that

was a mere consequence of the liability to

indemnify the Bank. It was rather a means of

satisfying the primary liability to indemnify

than a separate and independent liability.

The reference to the liability arising is speaking only of the need for performance, as His Honour

clearly says that the liability was not dependent

on any contingency once the bills had been

discounted.

Your Honours, where the bill is in the hands

of a third party, in practice there are three ways

in which the party accommodated can indemnify save

harmless the accepting bank. One is to pay the
bill itself at maturity. The old cases say to take
up the bill at maturity. The other is to put the

accepting bank in funds in advance. The third way

of indemnifying the bank, although I will say more

about this later - is to let the bank pay and then

reimburse the bank. The way it was described

frequently in the court below was you either take

up the bill yourself or you pay the bank in the

morning or you pay the bank in the afternoon. In

the case of two of these banks, they were paid in
the morning - they did the debiting themselves, of

course - and in the case of one bank, it was paid

in the afternoon.

His Honour Mr Justice Aickin refers to this

matter at the foot of page 201, where His Honour

says, about seven or eight lines from the bottom:

Coles(2) 21 5/5/92

The Company was however at liberty to draw on

the facility in part or in full from time to
time and could satisfy its obligation to

indemnify in respect of each bill by putting

the Bank in funds to meet the liability or by

paying the Bank after it had met its liability

to the holders, using for that purpose funds

from any source it chose. Indeed it could

have acquired the bills from Tricontinental or

subsequent holders and cancelled them.

Of course, we know in this case that did not

happen.

So our first respectful submission is that it

is consistent with what is said in K.D. Morris not

only by Your Honour the Chief Justice and

Mr Justice Aickin, but also by Mr Justice Stephen

and Mr Justice Wilson, to regard the obligation of

the party accommodated, the appellant, to the

accommodation party, the bank, as a present

obligation from the time of discounting, even

though of course it has to be performed in the

future.

The second of the submissions was that the

test is not a reciprocal cause of action, and that

submission is perhaps clear enough. If

Your Honours go, briefly, to the respondent's

written submissions, in paragraph 10, the Court
will see my learned friend's submission that the

appellant:

came under no liability to indemnify the bank

until the bank had paid the holder of the

bill. Until that even occurred, there was no

doubt between CMF and the bank.

And in 11:

Even in equity, the bank as surety had no
right to relief against CMF as principal
debtor until the time for payment had arrived.

Now, it is true that until the day of maturity the

bank would have no cause of action against the

appellant, how could it, and it is true that until

the day of maturity there is no debt, in the strict
sense of the word. There is a present obligation
to indemnify but there is no debt in the strict

sense, but they are not the test.

BRENNAN J:  The test of what?

MR CALLAWAY: Simply whether as a presently existing

pecuniary obligation, Your Honour.

Coles(2) 22 5/5/92

BRENNAN J: But the test of what is deductible under

section 51?

MR CALLAWAY:  A test of whether it is incurred under

section 51, Your Honour. It has, of course, to be

of a revenue nature and so forth, but this case is

solely concerned with the time of incurring.

BRENNAN J:  You are not seeking a deduction of the amount

for which they are liable, you are seeking a
deduction for something which is a balance and a

balance struck within the income year?

MR CALLAWAY:  Yes, Your Honour.
BRENNAN J:  Why do you, in striking that balance, take the

amount that will be payable in the following income

year and use that as your measuring stick?

MR CALLAWAY: Because, Your Honour, in the year of income,

if one takes a bill for $100,000 that is discounted

at $96,000, in the one year of income one both

receives the $96,000 and comes under what we submit

is a presently existing obligation to pay $100,000.

It does not matter that that is to be discharged in

the next year of income - - -

BRENNAN J: Why not? If you are trying to get a balance,

why do you not take the present value of that

debt - that existing debt?

MR CALLAWAY: 

That would run counter to the nominalist theory of money, Your Honour.

BRENNAN J: 

Of course it does, but you are not seeking to rely upon the nominalist theory of money, as I

understand it.  You are saying that you are not
seeking to characterize the liability under these
instruments as a 51(1) deduction, you are seeking a
balance which is arrived at by taking one amount
from another, one amount payable at one time and an
amount payable at another, and if you are striking
a balance, it seems to me, you are in the area of
value, not of nominalist figures. Nevill's case
was quite different.

MR CALLAWAY: Nevill's case, the promissory note case,

Your Honour, yes.

BRENNAN J: 

I am sorry, not Nevill - Nilsen's case was quite different.

MR CALLAWAY: Nilsen's case, with respect, indeed, is

different.

BRENNAN J:  Of course.
Coles(2) 23 5/5/92
MR CALLAWAY:  Yes. I should say - not that this binds the

Court but - both parties below were content to

regard the better analysis as, that it was a loss

rather than an outgoing, but we have always been

conscious that it might be said that it should be
regarded as an outgoing and that is something that

we address in paragraph 45(b) of our submissions.

I should mention that as a partial answer to

Your Honour's question too.

In the part of the respondent's written

submissions to which I was referring a moment ago,

having said correctly that there is no cause of

action until the day of maturity and that there is

no debt in the strict sense until the day of

maturity, the conclusion sought to be drawn from

that in paragraph 12 is that the appellant's

position is, therefore, essentially the same as

that of the taxpayers in Nilsen and Bendix. I have

said why we submit it is not at all like Nilsen.

There is no need to take the Court to it, but

Bendix was the case of liability on a guarantee,

but at page 562 of the judgment in Bendix, the
learned judge explains that the liability on the

guarantee was subject to receiving a written

demand, and no written demand had been received, so

there was a condition precedent to liability that

had not been satisfied in the year of income.

There is no condition precedent to liability

unfulfilled in the year of income in respect either

of the notes or the bills.

I have submitted from time to time that the

test is not whether it is a debt. That is

illustrated by a case such as Commonwealth

Aluminium, where at the end of the relevant year of

income, which was 31 December 1974, one could only

estimate the amount of royalties that would have to

be paid. If one could only estimate the amount of
royalties that were going to be paid there was not

a debt incurred in the year of income. the meaning of section 51 and that case, along with

Commercial Union and RACV Insurance, was approved by Your Honour the Chief Justice and two other

members of the Court in Nilsen. So, one can have a

presently existing liability short of a debt that

is nevertheless incurred for the purposes of

section 51.

The fourth of the five submissions had to do

with distinguishing the position on an

accommodation bill from the ordinary principal and

surety. It is a matter that we address in

paragraphs 31 and 32 of the written submissions.

The ordinary principal and surety is a case where

Coles(2) 24 5/5/92

the principal debtor is the person primarily liable

to pay. The surety, the guarantor's obligation, is

a contingent obligation if the principal debtor

defaults and, of course, if, and only if, the

surety has to pay, then the principal debtor has to

indemnify him.

In the case of an accommodation bill, the

surety, the acceptor, is the principal debtor

according to the tenure of the instrument. The
obligation of the party accommodated, the

appellant, is not an obligation that arises if an

event occurs, the principal debtor defaulting. It

is an obligation to be performed when the bill

matures. The bank's obligation as acceptor is
manifestly a present obligation from the day of

discounting and, in our submission, the obligation

to indemnify the bank is an obligation that

subsists from the time of discounting which will be

performed at the date of maturity. It is not a

matter of, "Look, we'll pay out if somebody else

defaults".

I labour this point a little because no doubt

it is always the fault of those who·draft these

things, but our paragraph 32 has evidently caused

some misunderstanding with our learned friends and,

from what they say about it in their paragraph 17.

We are not, for one moment, suggesting that either the bank's liability as acceptor, or our liability

to indemnify the bank, is a liability which arises in the future. The liability arises on the day of

discounting, but, of course, it is to be performed

in the future. But that is the point: it will be

performed in the future. It is not a contingent

liability to be performed, if need be, in the

future.

But fundamentally one comes back to the fifth

submission on this branch of the case. If
Your Honours would go - I think it is probably best to do it by way of developing two paragraphs of the
written submission, those paragraphs being 26
and 27, read in conjunction with the respondent's
paragraphs of 7 to 9. There we say that the
appellant's primary obligation was to indemnify the
bank and that, of course, is a quotation from
Mr Justice Aickin, or virtually a quotation, not
withstanding that the obligation could be satisfied
in several possible ways. Now those possible ways
are taken up by the respondent in its paragraphs 7
to 9. My learned friends say:

The acceptance of the bill by the bank gave

rise to an implied contract of indemnity. In

consideration of the bank's lending its name

by accepting the bill drawn on the bank, CMF

Coles(2) 25 5/5/92

impliedly agreed to indemnify the bank against
loss by reason of its acceptance -

and, with respect, that is a happier way of putting it, perhaps, than some of the ways that we have put

it. The obligation of indemnity is to indemnify

the accommodation party against the consequences of acceptance. That is the true formulation. So that will cover the case where the bill is held at

maturity by the accepting bank. Then my learned

friends say:

Absent any agreement to the contrary, the

obligation to indemnify the bank could be

performed by CMF, at its own election, in "any

of the ordinary modes of indemnification".

Now, to be fair, that was the submissions of both

parties in the court below, but reflection

suggests, with respect, that it is an

oversimplification.

If I draw a bill - an accommodation bill - on

someone as acceptor and that person agrees to

accept the bill for my accommodation and the bill

is then held by a third party, as all these bills

were, if I am to indemnity the acceptor, the only

two ways I can do it are to take up the bill myself

on the day of maturity or to put the acceptor in

funds in advance. A person is not truly

indemnified if he is required to pay the bill

himself and then is reimbursed in the afternoon.

One tends to overlook it with a bank because

it is easy for the bank to pay the bill at

11 o'clock and then debit the account. But if one

thinks of individuals, clearly, the acceptor is

entitled to be put in funds. The acceptor is not

exposed to having to raise money himself, herself

or itself, and pay the bill and then turn to the

accommodated party and say, "Please reimburse me?"

because the contracted accommodation is not that

the acceptor will pay the bill and then turn to the

accommodated party for indemnity.

The contract is that as between them the party

accommodated will be regarded as the real acceptor

of the bill. It is from that that flows the

obligation to indemnify the acceptor if the bill is

in the hands of a third party who is going to come

and demand payment; and you can only be

indemnified by those two ways.

We submit, with respect, that that must be

right, as a matter of principle, and it derives

support from something that was said by Sir Samuel Griffith in Rankin v Palmer,

Coles(2) 26 5/5/92
(1912) 16 CLR 285. On the last line of page 290,

His Honour quoted - I think it was

Lord Justice Buckley - for the proposition:

that "indemnity requires that the party to be

indemnified shall never be called upon to

pay ..... " -

of course, that means to pay out of his own funds.

So that the rider that we would respectfully

attach to paragraph 8 of my learned friend's
written submissions is that strictly speaking the

only true modes of indemnity where the bill is in the hands of a third party are taking the bill up

yourself or putting the bank in funds. The

practice of the bank, of course, which is content

to pay the bill and debit the amount later shows

there is no breach of contract. But a paradigm

accommodation bill must be of that character.

It is instructive, in our submission - I

foreshadowed this earlier - to consider the

position if the bank had held the bill to maturity. sometimes the successful tenderer was the accepting bank but paragraph 12(i) says the accepting bank never held at maturity.

I invite the Court to consider what would have happened if the accepting bank had held at

maturity: section 66 would have meant that the
bill was discharged because it was held by the

acceptor at maturity but the bank would have given

value and the appellant would still have had to pay

the bank. It would have paid the bank in its

capacity as holder for value of the bill, pursuant

to the contract of accommodation under which it,

the appellant, is to be regarded as the real

acceptor. In other words, the bank would have been

entitled to come to the appellant and say, "I, the

bank, hold this bill, and if it were an ordinary

trade bill it would be discharged. But the bargain between us is that you will be regarded as the real

acceptor. As between us it is irrelevant that I,

the acceptor, hold the bill at maturity. As

between us, it is as if you were the acceptor and

if you, appellant, were the acceptor I'd be

entitled to come and ask you to pay the bill.".

That is exactly what the bank would be entitled to

do because it is an accommodation bill.

TOOHEY J:  Mr Callaway, could I ask you what I am sure is a

very naive question, but why is so much emphasis

placed on the word "incurred" in section 51(1)? If

certain that it would be overlooked and that that

was an error and, as we say, it is not reconcilable

with Nilsen.

Moving to Comalco, that was a case where, in

our submission - I should qualify its name at the

time, Commonwealth Aluminium - there had been a

complete subjection, and I refer - I am reading

from 77 ATC 4151 at 4162; that case is No 18 on

our learned friend's authorities. In the

right-hand column on page 4162, His Honour said, in

the second paragraph to begin on the column:

It is, I think, clear that the overall

effect of the new sec 70 of the Mining

Act ..... was that Commonwealth Aluminium became

liable to pay a royalty in respect of each

tonne of bauxite which itmined during the 1974 five months' period, so soon as that tonne was

mined. For those provisions imposed a royalty

liability upon Commonwealth Aluminium in

respect of all bauxite which it "won". Thus
once each tonne of bauxite was mined during

the 1974 five months' period, Commonwealth

Aluminium thereby subjected itself to a

liability to pay a royalty in respect thereof.

It was the mining of the bauxite which

attracted the liability, and once each tonne

had been mined, there was nothing more

required to be done by Commonwealth Aluminium

to subject itself to liability for the

royalty, and there was nothing which

Commonwealth Aluminium could do, which would

affect the amount of the royalty.

The main point of that case is that there had

been a complete subjection. There was, in our

submission, a statutory debt, the amount did

Coles(2) 88 5/5/92

require to be calculated, and there was no other

event, as there is, in our submission, here, on

which liability depended. As there was a statutory

debt it only needed to be quantified.

It is not unlike Re Mendonca, a case on income

tax and bankruptcy, which is not on our

authorities, Your Honours, and we can supply,

before the evening is out, the photocopies; Re
Mendonca, Ex parte Commissioner of Taxation,
(1969) 15 FLR 256. Mr Justice Gibbs, when in the

Federal Court of Bankruptcy, was considering liability for taxation for income tax and - this is

only an analogy but we submit that what His Honour

said at page 259, about point 7 on the page:

It is now settled that the effect of -

the various sections in the early 200 of the Income

Tax Assessment Act -

is that the liability to income tax is imposed

by the statute itself and that assessment is

only a method of ascertaining the extent of

the liability, so that the tax is a debt due

and owing, although not payable,

notwithstanding that no assessment has been

made.

And His Honour considers that at least by the end of the year, 30 June, there is such a liability

even though you do not know the figure at that
time. But we say that is a useful analogue to this

present case.

Your Honour Justice McHugh then raised with me

RACV and it may have been Commercial Union, again.

Those were cases, in our submission, where there

was a complete subjecting even though the figure

was arrived at by a soundly based estimation. The

present Chief Justice of this Court in Nilsen spoke

of the liability being incurred and in the passage

in his judgment the word "incurred" appears in

italics.

We would say that RACV, Commercial Union, so

far as it is similar to RACV, that is so far as it

is dealing with quantification, at any rate, are

not inconsistent with Nilsen and Flood. Commercial

Union may be inconsistent in its treatment of the

condition precedent unless it is right to treat it

as wiped out altogether. I think I have dealt with

the cases that Your Honour raised with me.

My learned junior reminds me of Ogilvy &

Mather, which we have listed about a third of the

way down page 2 of our outline. It is Ogilvy &
Coles(2) 89 5/5/92

Mather, (1990) 98 ATC 4836 - I will not go to it at

the moment - a decision of the Full Court of the
Federal Court.

That was a case where an advertising agency which placed advertisements with media outlets

had - the time had run whereby it was in what was

called the non-cancellation period. So it had

asked for advertisements to be placed, the

non-cancellation period had commenced - that is to
say it was not able thereafter to withdraw - but
the Federal Court held that there was no present

liability until the advertisements were published

and the advertisements, although Ogilvy and Mather

could not thereafter stop the advertisements from

being published, they may not be published because

of a strike or some other printing problem and

therefore there was no liability accrued by the end

of the tax year.

MASON CJ: That may be a convenient time to adjourn,

Mr Batt. We will resume at 10.15 am tomorrow.

MR BATT: If the Court pleases.

AT 4.15 PM THE MATTER WAS ADJOURNED

UNTIL WEDNESDAY, 6 MAY 1992

Coles(2) 90 5/5/92
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Rankin v Palmer [1912] HCA 95