Commissioner of Taxation v Dalco

Case

[1989] HCATrans 199

No judgment structure available for this case.

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IN THE HIGH COURT OF AUSTRALIA

Office of the Registry

Sydney Nos S225, S226, S227 and S228 of 1988

B e t w e e n -

THE COMMISSIONER OF TAXATION OF

THE COMMONWEALTH OF AUSTRALIA

Appellant

and

JEFFREY THOMAS DALCO

Respondent

MASON CJ

BRENNAN J

DEA..l'm J

DAWSON J TOOHEY J. GAUDRON J McHUGH J

Dalco(2)

TRANSCRIPT OF PROCEEDINGS

AT CANBERRA ON WEDNESDAY, 6 SEPTEMBER 1989, AT 10. 19 AM

Copyright in the High Court of Australia

Cl Tl /1 /ND 1 6/9/89
MR K.R. HANDLEY, QC:  In these appeals, if the Court pleases,

I appear for the appellant with my learned friend,

MR D.B. McGOVERN. (instructed by the Australian

Government Solicitor)

MR D.F. JACKSON, QC:  May it please the Court, I appear with

my learned friend, MR P.M. WOOD, for the respondent

in each appeal. (instructed by J.C. Behm &

Associates)

MASON CJ:  Yes, Mr Handley.
MR HANDLEY:  We have here our outline, Your Honours, together

with the key sections of the 1986 Act which was

in force at the time the appellant's objections

were transmitted to the Court.

MASON CJ:  Thank you.

MR HANDLEY: If the Court pleases, I would seek to identify at the outset the principal findings of fact that

Mr Justice Yeldham - not the evidentiary facts

but his ultimate findings, and they can conveniently

be found on three pages of volume I of the appeal

book, page 157, firstly, commencing at line 12:

I am quite satisfied from the evidence as a whole that during the years under

consideration the taxpayer completely
disregarded corporate structures and

entitlements or used them purely for

convenience in the lending of money and the

claiming of expenses, so far as CCS -

Corporate Consultants was one of the taxpayer's

controlled companies -

and the other companies with which he was

connected are concerned, and the entitlement
of "Sydney" to its share of the net proceeds.

I consider that in each of the years of income

there was a derivation of income by the
taxpayer that was dealt with at his direction
with a disregard of corporate rights.
Clearly he lived at a rate beyond his
disclosed cash income and had control of large
sums of money in respect of which there was
no proper accounting or adequate explanation,
and none has yet been given.

Going to page 158, line 22:

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Dalco(2)
MR HANDLEY (continuing): 

Much of his evidence I found unsatisfactorv.

At the very least he had the control and

benefit of the moneys which the Commissioner
has included as assessable income during

the years in question or their equivalent.

It is plain from the auth~rities that

the onus is upon the taxpayer to demonstrate

that the Commissioner's figures in relation

to taxable income were excessive, by showing

the sources of that income year by year

and excluding all sources of income other

than those which he admits. That onus has

not been discharged as there were funds
available to him from unexplained sources
year by year and shortages of income in each

year that were and are unexplained in a

satisfactory manner.

Then at page 161, after some discussion of the

authorities, His Honour said, line 25:

Applying the foregoing principles to this case I am of the opinion that the taxpayer

has failed to prove that any relevant

assessment is erroneous or excessive.

The matter went on appeal, as Your Honours know, to

the Federal Court, where the appeals, by maiority, were
allowed, and if I could identify the key passages in

the reasoning of the ma.iority commencing at page 198,

line 9:

Where, as in the present case, an

assessment is a default assessment produced

by the operation of ss. 166 and 167 -

that is where the Commissioner assesses otherwise than

in accordance with the taxpayer's return and contrary

to the return - there is involved as a necessary step in
the process of assessment the ma~ing by
the Commissioner of a "iudgment" as to
the amount upon which income tax ought
to be levied. ·

(Continued on page 4)

ClT2/l/HS 3 6/9/89
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MR HANDLEY (continuing): 

Accordingly, in a particular case, a

default assessment may be made, to adopt the

language of Taylor J, (in ..... McANDREW' s case) ,

in purported but not justifiable exercise of a statutory power, namely the power of the Commissioner to make an assessment of

the amount upon which in his judgment income

tax ought to be levied within the meaning of section 167; to apply the reasoning of

Dixon CJ, McTiernan and Webb JJ in the

same case ..... the making of a judgment
within the meaning of section 167 went to
the authority of the Cormnissioner to

impose the liability by default assessment. In due course, Your Honours, we will be submitting

that in that passage the majority misunderstood

McANDREW's case and decided in the teeth of

GEORGE's case. But, I would only wish before

proceeding to identify - go back and look at one

short passage in that section at line 11 where

Their Honours say:

There is involved as a necessary step in

the process of assessment -

Now, it is the process of assessment, in our

submission, which is shielded from judicial review

in the appellate process permitted by the Act which

narrows the issue, in our submission, to the

substantive liability of the taxpayer to tax so
that, in our submission, at this passage the majority

are also proceeding contrary to section 175 of the

Act which, as we will endeavour to demonstrate,

protects the process of assessment from judicial

review in the statutory appeal.

(Continued on page 5)

ClT3/l/JH 4 6/9/89
Dalco(2)
MR HANDLEY (continuing):  Then going to page 200, line 16:

The making of a purported judgment for the purposes of ss. 166 and 167 may also be

impeached if the Commissioner proceeds upon
a "wrong basis" or upon a "wrong principle",

for example, by treating a taxpayer on an

earnings basis, when the taxpayer should have

been treated on a receipts basis. The

taxpayer submitted that the Commissioner

proceeded upon a wrong basis in respect of

each of the years of income in question.

Your Honours, we do not challenge, in any way, the

power and the duty of a court hearing a statutory
appeal against an income tax assessment, in an
appropriate case, to set aside the assessment on

the basis that the Commissioner has proceeded upon

a wrong basis or upon a wrong principle. But, in

our submission, an essential foundation for that

exercise of jurisdiction is the establishment by
proof or by admission of the basic facts relevant

to the assessment. If the taxpayer fails to

identify, by proof or by admission, what the basic

facts are it is nothing to the point that he can

entirely consistent with an assessment which has

suggest that there has been some error in the

not been shown to be excessive. And more of that
in a moment. Line 25: 

If it appears that an assessment has been made

in purported but not justifiable exercise of

statutory power, so that it is excessive in the

necessary sense, then the appropriate course

is for the Commissioner to make a new assessment

in the light of the Court's decision.

(Continued on page 6)

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Dalco(2)

MR HANDLEY (continuing): In our submission, apart from the

very special case of amendments outside the prima

facie time limits in section 170, one cannot attack

an assessment of income tax on the basis that it

was made ''in purported but not justifiable exercise of a statutory power", if the notices of assessment are tendered in evidence as contemplated by

section 175. Their Honours go on:

Accordingly, the appropriate order is

for the remission of the assessment to

the Commissioner for re-assessment -

and then, over to 226, at the very end of their

judgment, at line 17:

His Honour -

that is the trial judge -

approached the matter by enquiring whether

Mr. Daleo had established that the income

he in fact received in each of the tax years

was below the amount of the assessment arrived

at by the Commissioner. On the facts of these
cases, we have concluded that the answer to this

inquiry will not necessarily be determinative of

what the outcome of the appeals should be. That

is because it was open to the taxpayer to endeavour to demonstrate that each of the assessments (that is, each of the processes of
assessment) was excessive in that it was not

warranted by law. It is that submission which
we have accepted, but we make it clear that we

do not find error in his Honour's findings of

fact that Mr. Daleo did not show that in fact his income for each of the tax years was less

than the figure arrived at by the Commissioner,

and did not show that his only income was

disclosed in his income tax return.

In those few lines, Your Honours, the majority have

encapsulated the issue before this Court, because

no doubt, my learned friend will seek to support the

majority view at the bottom of page 226. We submit

that is fundamentally wrong and that the majority,

having concluded that the trial judge could not be

challenged in his findings of fact on the appeal-

the inevitable result, in our submission, should have

been consistently with the statute and with the

decided cases, is that the appeal should have failed

to the Full Federal Court.

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MR HANDLEY (continuing) : Can I just remind Your Honours, briefly, of the

key sections of the Act. These have hardly changed

since 1936 and in 1936 they barely changed from

the position which·· had governed tax appeals since

1922. Sections 166 and 167-need f~rst to be

looked at. I gave Your Ronours the sections.
Section 166: 

From the returns, and from any other information in his possession, or from any one or more of

these sources, the Commissioner shall make an

assessment of the amount of the taxable income

of any taxpayer, and of the tax payable thereon.

And 167 is the default assessment section. This

was the section used by the Commissioner in this case

because he amended assessments and the new assessments
diverged markedly from the returns made by the

taxpayer.

If -

(a) any person makes default in furnishing a return;

or

(b)

the Commissioner is not satisfied with the return furnished by any person; or

(c) the Commissioner has reason to believe that
any person who has not furnished a return
has derived taxable income,

the Commissioner may make an assessment of the

amount upon which in his judgment income tax ought to be levied, and that amount shall be

the taxable income of that person for the

purpose of section 166.

And this Court in GEORGE's case considered the

operation of those sections in relation to the

appeal jurisdiction established by the Act. (Continued on page 8)
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Dalco(2)
MR HANDLEY (continuing):  Then we can go to section 175:

The validity of any assessment shall

not be affected by reason that any of the
provisions of this Act have not been complied

with.

And then 177(1):

The production of a notice of assessment, or of a document under the hand of the

Commissioner ..... purporting to be a copy
of a notice of assessment -

and those words pick up a notice of an amended

assessment as well as a primary assessment -

shall be conclusive evidence of the due

making of the assessment and (except in
proceedings on appeal against the assessment)
that the amount and all the particulars of

the assessment are correct.

So that section 175, read with section 177 and

read with section 190, which is to come, in our

submission, shield from judicial review in the

statutory appeal any examination of the means by

which the Commissioner arrived at his decision

and focused the issue on the taxpayer's substantive

liability for tax.

The remaining section is section 190(b).

In proceedings under this part, on appeal to a

court:

the burden of proving that the assessment

is excessive shall lie upon the taxpayer.

(Continued on page 9)

C 1T7 /1 /ND 8 6/9/89
Dalco(2)
MR HANDLEY (continuing):  One of the questions is whether

"excessive" is limited to excessive in amount or

whether, as the Federal Court have held, "excessive"

is the result of an unauthorized judgment process,

or decision-making process, on the part of the

Coo:m.issicmer. I would like now, if I may, with the

benefit of those sections, to spend another moment

or two with the majority judgment commencing at

page 196. At page 196 and following the majority

are looking at the meaning of the word "excessive"

in section 190(b) and that appears from line 2, but

going down to line 14:

In McANDREW's case Taylor a.

dealt with a submission that to show that an

assessment was not in the circumstance

authorised at all was not to show that it was
"excessive"; the submission was that that
expression was limited to questions relating

to the quantum of the assessment, and did not

extend further. Taylor J. held that the

word "excessive" was capable of a much wider
meaning than that ascribed to it by this

submission, and his Honour said:

"There is no reason for thinking that an

assessment, made in purported but not justifiable

exercise of a statutory power, may not properly

be described as excessive; it purports to impose

a specified liability and, upon appeal, the

claim of the appellant is that he is not liable

to pay any part of it. Whether the particular

ground upon which he seeks to escape or reduce

the liability merely touches the accuracy of the assessment or assails its validity as an

assessment, he is, in the words of s. 185,

"dissatisfied with" the assessment because it

purports to impose upon him a liability in

excess of that to which he may lawfully be

subjected and I can see no reason why, in

either case, his complaint may not be

accurately described as a complaint that his

assessment is excessive."
Your Honours, it will be necessary to take the

Court, as briefly as possible, to McANDREW's case

but it is sufficient, at this stage, simply to say

that McANDREW's case was concerned with an amended

assessment and the taxpayer alleged, among other

grounds, that the assessment was out of time and

that the period within which the Corrmissioner could ammd

had expired , whereas the Commissioner asserted that

that period had not. This threw up the issue under

section 170(2). Your Honours will see that from

McANDREW's case in due course, that there were

apparently statutory conditions precedent in

section 170(2) to an amendment after the six-year

ClTS/1/DR 9 6/9/89
Dalco(2)

period, namely, that the taxpayer had not made a

full and true disclosure of all the material facts

and there had been an avoidance of tax. The taxpayer's

attack on the amended assessments included an

assertion:

that he did make a full and true disclosure -

and -

that there has not been an avoidance of tax.

That was with issue with which this Court grappled in McANDREW's case but it is important to

note, of course, that if the Commissioner could not

amend, because the statutory conditions precedent

had not been fulfilled, he was not entitled in law

to increase the taxpayer's original assessment by

as much as a single pound. So, by attacking the

legal validity of the purported exercise of the

power to amend the assessment, the taxpayer was also

saying, "I don't owe, legally, any part of the sum

for which I have been assessed in the amended

assessment."

(Continued on page 11)

ClT8/2/DR 10 6/9/89
Dalco(2)
MR HANDLEY (continuing):  So the challenge went to the

quantum of the assessment and Mr Justice Taylor

picks that up in the passage quoted by the

majority at the bottom of page 196 at line 28:

the claim of the appellant is that he

is not liable to pay any part of it.

And McANDREW could show that by showing that the

statutory power to amend had not arisen because

the conditions precedent had not been fulfilled.
But, when we come to Mr Daleo, he was not able,

in the process which was accepted by the majority

of the Full Court, to say that, "I am not liable

to pay any part of these amended assessments at

all"; all he was able to say is, "The Connnissioner

has gone the wrong way about assessing me".

And, it really shows that distinction - what we

have just put, in our submission, highlights the

difference between McANDREW's case, where an attack

on the power to issue an amended assessment went

directly to the excessiveness of that assessment,

on the one hand, and in DALCO's case, on the other,

where Mr Daleo has been allowed to attack the

assessment on legal grounds without showing that it

is excessive to any extent or that he is not liable

to pay any part of it.

If I could then go to page 198, line 9:

Where, as in the present case, an assessment is a default assessment produced by the

operation of sections 166 and 167 ..... there

is involved -

I read this passage to the Court already, I am sorry,

so I need not read that again and I need not

trouble Your Honours, I do not think, with the rest of the majority judgment; I think we have been able to isolate the key passages subject to anything that

my learned friend may say. Can I take Your Honours

now to the dissenting judgment in the Full Court

of Mr Justice Wilcox and seek to identify the key

passages there, connnencing at page 252, line 17:

It seems to me that these submissions

fundamentally misconceive the nature of

the task upon which this Court is engaged.

Because this question lies at the heart

of this case, and because my view

differs from that taken by -

the majority -

ic is necessary for me to discuss at some length the issue for the Court. It seems to me to be clear that the issue before

ClT9/l/JH 11 6/9/89
Dalco(2)

this Court, like the issue before the

Supreme Court, is not whether the

particular assessments ultimately made

by the Commissioner in each year

evinced any error but whether, in

relation to any of the relevant years, the amount of taxable income for which

Mr Daleo was assessed exceeds his actual

taxable income.

We would respectfully adopt that view.

It is, of course, entirely possible that

an assessment which is in fact erroneous -

that is erroneous in the way in which the Commissioner

has gone about it -

will show a taxable income which is in

fact no more than the taxpayer's actual

income.

Then, dropping down to line 14:

In McANDREW V COMMISSIONER OF TAXATION

..... Dixon CJ, McTiernan and Webb JJ,

speaking of section 190(b), said that

"the word 'excessive' relates to the

amount of the substantive liability".

Therefore the task for the taxpayer, upon an appeal or a review under Part V

of the Act, is to show that the amount

of money for which tax is levied by a

particular notice of assessment exceeds

the actual substantive liability of

the taxpayer.

(Continued on page 13)

ClT9/2/JH 12 6/9/89
Dalco(2)

MR HANDLEY (continuing):

Most commonly the taxpayer will discharge

this burden by demonstrating that his or

her true taxable income is less than that

adopted by the Commissioner for the purpose

of computation of the amount of tax payable

by the taxpayer. But the taxpayer may

discharge the onus by showing that, although

the figure adopted as taxable income is

correct, the Commissioner adopted an

incorrect tax rate; or made some error of

computation. Alternatively, as McANDREW points out, the taxpayer may demonstrate excessiveness by showing non-compliance with

statutory conditions precedent to the

imposition of a particular liability, so that

the liability purported to be imposed by the

Commissioner is one not lawfully able to be imposed.

And then, if I could turn to 261, the top paragraph:

Nothing in McANDREW derogates from the

principle that the onus lies upon a taxpayer

to demonstrate, not merely that an assessment

is wrong, but that it is excessive. In

McANDREW the contest between the parties

apparently turned upon the question whether

there had been a failure to make a full and

true disclosure and/or whether there had been

an avoidance of tax. Taking the view that

the Commissioner bore no onus to establish

the existence of s. 170(2) circumstances -

they are the ones just referred to~

each of the High Court Justices was concerned

to point out that, nonetheless, the matter

of compliance with the conditions specified

ins. 170(2) was a subject able to be

investigated upon the appeal, the onus lying
on the taxpayer to negative compliance. The
matter of compliance with those conditions
was able to be investigated, despites. 177,
because it was a matter going to the
correctness of the amended assessment.

Then, over to 266, the last paragraph:

The present case is not one, like that

envisaged in McANDREW, of a demonstrated

failure of the statutory conditions precedent

to the imposition of liability. There is here no question about the entitlement of

Cl Tl O /1 /ND 6/9/89
Dalco(2)

the Commissioner to issue the relevant

amended assessments. The question is

merely whether the amounts of taxable income

shown in those assessments are excessive.

It is not enough for the appellant to raise doubts as to the correctness of the figures adopted by the Commissioner, or even to

demonstrate that Mr Kidd's reasoning is

faulty.

Mr Kidd was an investigator who wrote reports on

the taxpayer's affairs and which reports went into

evidence.

In respect of any particular year he must

show that the adopted taxable income exceeds

his actual taxable income.

And then, at 274, in conclusion, the last paragraph,

His Honour said:

I share the view of Yeldham J that the

appellant's assertion that his only income

in the relevant years was that declared in
his various income tax returns cannot be

accepted; at least in the absence of evidence

such as I have mentioned. The appellant

failed to make out his case in the Supreme Court. His appeals were rightly rejected.

Your Honours, that sets the stage for a brief look

at the key decisions, prior decisions of this Court,

and would propose to take Your Honours to the

cas s referred to in our outline, GEORGE, McANDREW
and BLOEMEN, as briefly as possible in order to
demonstrate the divergence between the majority
view and the view hitherto accepted by this Court.

GEORGE's case is reported in 86 CLR 183.

It did not concern the hearing of an appeal against

a default assessment under section 167. The issue

before a Justice of this Court and then the Full

Court was whether the taxpayer who had been

assessed - default assessed - under 167 was

entitled to an order for particulars but, in the

course of deciding that issue, this Court made

important observations on the true effect of the

sections of the Act which govern statutory appeals

against assessments.

I do not think I need trouble Your Honours

with the headnote or the facts beyond noting that

it was a case of a default assessment and a request

for particulars. And then, going to page 189 in

the judgment of Mr Justice Kitto, in the first

instance - there is a reference on the right-hand

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margin to section 190(b) about a quarter of the

way down the page:

Buts. 190(b) places the burden of proving

that the assessment is excessive upon the

appellant; and in order to carry that

burden he must necessarily exclude by his
proof all sources of income except those

which he admits. His case must be that he

did not derive from any source taxable

income to the amount of the assessment.

(Continued on page 15)

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MR HANDLEY (continuing):

That will involve him, of course, in

accounting for the increase in his

assets, and it may well be that the

commissioner will direct his efforts

mainly or even wholly to endeavouring to

meet the evidence the appellant adduces

on this point. But the source of the

increase in the assets is not the actual

issue in the case; even if it were

proved, for example, that that source

consisted of winning bets on the racecourse,

the issue would still be whether or not

from any source the appellant derived as

much taxable income as the assessment

treats him as having derived.

Then I do not need to trouble Your Honours with the
rest of that page, or the rest of the iudgment of
Mr Justice Kitto. Going to the Full Gour~ at
page 201, in the ioint iudgment commencing at the
top of the page, Their Honours say:

Section 190 provides that upon every

appeal to the Court the burden of proving

that the assessment is excessive shall lie

upon the taxpayer. With this provision must

be reads. 177(1) which provides that the

production of a notice of assessment ..... shall

be conclusive evidence of the due making of

the assessment and (except in proceedings on

appeal against the assessment) that the amount

and all particulars of the assessment are

correct. The word "assessment" is defined bys. 6(1) to mean the ascertainment of the

amount taxable income and of the tax payable

thereon.

'1\scertainment", Your Honours, has been interpreted in this Court as not meaning the discovery but the

fixation, and fixation by the actual notice of

assessment, and more of that in due course: In conformity with this definitions. 166
directs the commissioner to make an
assessment ..... From these provisions both
in their present form and in their slightly

different earlier form, the law has always been taken to be that in an appeal from an

assessment the burden lies upon the
taxpayer of establishing affirmatively that
the amount of taxable income for which he
has been assessed exceeds the actual taxable
income which he has derived during the year f .
o_ income.
There 1s a reference to the iustice of that burden:
ClTll/1/HS 15 6/9/89
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In the present case it might be
expected that the source of the large

increase year by year in the appellant's

assets would be a matter peculiarly within

his own knowledge. If it is a form of gain

outside the very wide ambit of what is
assessable income, the proof of its
character will be enough to support the

material grounds o: his appeals. It is

a fact outside any knowledge the

commissioner can have except from inquiry

into the affairs of the appellant and it

is not unreasonable that the onus of proof

sh o u 1 d be placed by 1 aw upon the 1 a t t er .

Then at page 202 and following there is a discussion

of the question of whether section 167 creates a

statutory condition precedent to the power to

issue a default assessment and, in our submission,

the maiority have revived this doctrine which was

earlier dec1sively reiected in GEORGE's case by

the Full Court of this Court. If I could iust pick

up a sentence at page 202 in ~h.e last paragraph:

The contention -

that is of Mr Barwick of King's Counsel, as he then

was, for the taxpayer -

is that before the commissioner may fix

the taxable income under s.167(b) two

conditions must be fulfilled and that,

in an appeal, the burden is upon him -

that is the Commissioner -

to prove their fulfilment.

I need not read on from there, but going to page 203,

Your Honours, about point 7 on the page - the words

"no foundation" are on the left-hand margin, and tl-ie

sentence above that:  The assumption made -

that is about these conditions precedent -

however, has no foundation. The

formation of the iudgment as to what is the

amount of the income that ought to be taxed

is no condition precedent to the power to

assess. It is part of the very process of

assessment itself.

Of course, Your Honours, pausing there, as such it 1s

protected from iudicial review, in our submission,

in the statutory appeal by a combination of

section 175 and section 177(1).

ClTll/2/HS Hi 6/9/89
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MR HANDLEY (continuing): Section 166 ands. 167 do not

prescribe distinct duties or functions.

They combine to show what the commissioner

may or must do in performing his single duty

of arriving at an assessment.

I need not trouble Your Honours with the rest of

that page. Going over the page to 204, line 5:

Just as under s.166 considered alone the

commissioner ascertains the amount of the

taxable income and thus assesses it so does

he under s. 167, used in aid of s.166,

ascertain the amount upon which, in his

judgment, income tax ought to be levied and

thus assesses it. By definition "assessment"

means the ascertainment of the amount of the

taxable income, and of the tax payable thereon.

Pass over the next sentence.

The fact is that unless the taxpayer discharges

the burden laid upon him by s.190(b) of

proving that this ascertainment or judgment is

excessive, he cannot succeed and it can be no

part of the duty of the commissioner to

establish affirmatively what judgment he formed,

much less the grounds of it, and even less still

the truth of the facts affording the grounds. Yet
that is what is involved when the demand for
particulars of the sources alleged of the
appellant's income is justified by reference
to s. 167. It is an error to treat the
formation by the connnissioner of a judgment as

to the amount of the taxable income as if it were

not the ascertainment of the taxable income which

constitutes assessment or a necessary part of that

process and as if it were but the fulfilment of a condition precedent to the power or authority to assess. If, however, it were a condition
precedent the question would at once arise

whether the fulfilment of the condition was not
part of "the due making of the assessment"
of which s. 177(1) makes the production of a
notice of assessment conclusive evidence.

And then going to pages 206 and 207 - the bottom of

page 206 the words "Department of Taxation appear
between the right and left-hand margins - Their

Honours go on to say:

But in any case the question whether the right

officer has applied his mind to the question

whether the taxpayer's returns are satisfactory

within s.167(b) is not a question left open by

s.177. As already has been said, ss.166 and 167
CIT12/l/CM 17 6/9/89
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are together concerned with the process of

ascertaining the taxpayer's taxable income and

the consequent tax. The clear policy of

s.177 is to distinguish between the procedure

or mechanism by which the taxable income and

tax is ascertained or assessed on the one hand

and on the other hand the substantive liability

of the taxpayer. The former involves the due

making of the assessment.

Going down to the last few lines of that long

paragraph:

Obviously the 'due making of the assessment"

was intended to cover all procedural steps,

other than those if any going to substantive

liability and so contributing to the

excessiveness of the assessment, the thing

which is put in contest by an appeal.

Mr Justice Fullagar added short reasons, although

he was a party to the majority judgment - I need

not trouble Your Honours with those. In our

submission, Your Honours, GEORGE's case establishes

that default assessment under section 167 does not

depend upon compliance with any condition precedent~

that in any event_ the question of such compliance

is protected from judicial review on the statutory

appeal because it forms part of the due making of

the assessment and it indicates that on the

statutory appeal the sole issue for the appellant

court, I realize it is not a tru2 appeal, is the

substantive liability of the taxpayer and the

statute sweeps to one side what I might call the

decision-making process.

Of course it is the decision-making process

which is central to the jurisdiction of the Federal

Court under the ADMINISI'AATIVE DEC.I:SIONS

(JUDICIAL REVIEW)ACT, but it is excluded from that

decision-making process, in our submission, apart

and the time limits is shielded from judicial from the very special case of amended assessments
review by sections 175 and 177.

(Continued on page 19)

CIT12/2/CM 18 6/9/89
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MR HANDLEY (continuing):  If we could now look at

McANDREW's case in 98 CLR which seems to have

been the source of some of the confusion in the

majority judgments, with respect; McANDREW, 98 CLR 263,

I will read the headnote if I may:

When upon an appeal to the Court against

an amended assessment there is an issue as

to whether the condition stated in

section 170(2) ..... are fulfilled and a

regular notice of assessment is produced

..... the burden rests upon the taxpayer

of proving to the reasonable

satisfaction of the Court the particular

fact or facts which take the case

outside section 170(2).

I need not read the rest of that paragraph. The
joint judgment: 

The word "excessive" ..... extends over the
area in which the conditions mentioned

in section 170(2) find a place. If the

commissioner cannot amend consistently

with section 170(2) and so increase the

amount of the assessment then it must

be excessive.

Going to the joint judgment which was concerned with

other issues as well, onus of proof and the like,

we can pass over those matters. To the top of
page 270, line 3: 

The ground over which section 177(1)

gives conclusiveness to the assessment is

described as the due-making of the

assessment and the correctness of the

amount and all the particulars of the

assessment. But that appears to us to

comprise the whole ground. It is the

manifest policy, one may now almost say

the historical policy, of the legislation
on the one hand to give to the taxpayer
full opportunity on objecting to his
assessment of contesting his liability in
every respect before a court ..... but on the
other hand to require that in proceedings
for the recovery ..... The question whether
the conditions laid down by section 170(2)
are fulfilled so that the commissioner
might amend the assessment is clearly
within this policy.

And, Their Honours say that it would be extraordinary

if that could be raised in answer to a recovery

action. Then, over on page 271, the last seven or so

lines of the first paragraph:

C1Tl3/l/JH 19 6/9/89
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An appeal, however, is a proceeding

given by statute to a taxpayer for the
purpose of impugning an assessment

otherwise conclusively imposing liability

upon him. If there were no more than

that, it would be enough to cast upon

the taxpayer the burden of establishing

his objections. On ordinary principles

he must establish the facts which give him a prima facie title to the relief he seeks from the Court.

But there is more than that.

The reference to section 190(b).

"Excessive" is the word chosen to correspond

with the word "amount" in section 177 (1).

That is important, Your Honours, because the

majority in the Federal Court, in our submission,

have overlooked that basic fact by treating

"excessive" as covering an erroneous decision-making

process regardless of its effect on the quantum of

the assessment, it overlooked the fact that "excessive"

is a slightly inappropriate but, nevertheless,

clearly enough intended reference to the amount of

the assessment and what was allowed to be done by
the Federal Court in this case was to attack the

assessment without attacking its amount.

BRENNAN J:  Well, the distinction which is relevant is that

in 170(2) we have conditions precedent to the

exercise of a power and in 167 we do not; was

that the situation?

MR HANDLEY:  Yes, Your Honour.
BRENNAN J:  And, I suppose the problem is how to reconcile

that difference of approach to the two sections.

(Continued on page 21)
C1Tl3/2/JH 20 6/9/89
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MR HANDLEY:  Yes, Your Honour. It really flows from the

very text of the sections themselves, in our submission.

And the way in which the due making of the assessment -

in McANDREW's case what this Court said was that

the conditions precedent in 170(2) were not part of

the due making of the assessment. Now there is some

tension in some of the language in these sections in

relation to the issue in McANDREW's case and the Court

was concerned to avoid two unpalatable results.

Firstly, that the onus was on the Commissioner and an

amended assessment could be challenged on conditions
precedent grounds in recovery proceedings, or in

bankruptcy proceedings on the one hand, while on the

other hand, the taxpayer could not challenge

compliance with the conditions precedent at all, because

they were part of the due making of the assessment,

and the Commissioner could point to 175 and 177(1) and

say that the satisfaction of those conditions precedent

is outside the scope of the appellate jurisdiction of the Court

tm.der the various sections tm.der Part V. So between putting the onus

on the Commissioner on the one hand, and shutting the

taxpayer out on the other, the Court was able to
treat satisfaction of the conditions precedent as not

part of the assessment process and therefore open to

examination in the statutory appeal. Those

considerations just have no part in section 167, both

on principle and on authority.

Reading on, if I may on 271, in McANDREW, after

the sentence dealing with "excessive":

The "amount" no doubt re::lects the

"particulars". It is perhaps not a good

choice. For the replacement bys. 190(b)
of the words which appeared in the
corresponding previous legislation in the
exception ins. 177(1) has perhaps caused

the difficulty. The words of the legislation

were "except in proceedings on appeal against

the assessment when it shall be prima facie

evidence only". But bearing in mind that the

word "excessive" relates to the amount of the substantive liability it is not difficult to
see that it will extend over the area in which
the conditions mentioned ins. 170(2) find a
place. For the fulfilment of those conditions

goes to the power of the commissioner to impose the liability by amendment. If he

cannot amend consistently withs. 170(2) and
so increase the amount of the assessment then
it must be excessive -

ie in amount. In the whole of that paragraph,

Your Honours, the joint judgment in McANDREW, is,

in our submission, inconsisteut with the view of the

majority of the Federal Court in this case, which

treated "excessive" as permitting an attack on an

ClT14/l/FK 21 6/9/89
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assessment independently of an attack on its

quantum, and an attack on an assessment independently

of the true substantive liability of the taxpayer

to tax. Going to Mr Justice Kitto's judgment -he

concurred - and we can go to 2 7 4, and then in the

first paragraph, commencing just below the rereren~ to section 170 ( 2) , in the middle of

that paragraph, Mr Justice Kitto says:

For that reason an objection that the

amendment should not have been made, whether

it is based upon a contention that the

commissioner has fallen into some error in

the course of making it or upon a contention

that the commissioner had no authority to

amend in the circumstances of the case, is an
objection that it has resulted in an

assessment fixing the taxpayer with a higher

liability than that which attached to him upon

a correct application of the Act as a whole.

It is therefore an objection that the amendment

has made the assessment excessive, whatever

the ground of objection may be.

(Continued on page 23)

ClT14/2/FK 22 6/9/89
Dalco(2)

MR HANDLEY (continuing):

In the absence of any other material

provision in the Act, this would mean that if a

taxpayer is to succeed in an appeal against an

amended assessment on the ground that the

amendment was unauthorised having regard to

s. 170(2), he must discharge the burden of

establishing one or more of four propositions

of fact.

Then, going to the bottom last three lines:

"Due making" in this context -

referring, of course, to section 177(1) -

is an expression which covers all procedural

steps, other than those (if any) which go to

substantive liability and so contribute to the
excessiveness of the assessment.

I do not think I need trouble Your Honours with page 275, but going to page 277, His Honour said -

at about point 6 on page 277 there is a reference

to "Pt. IV of the Act":

There is nothing to suggest an intention to

depart from the general policy, so clearly

evinced in Pt. IV of the Act (comprising

ss. 161 to 177) ands. 190(b), of making

all assessments unchallengeable except in so

far as the taxpayer may displace them on

appeal.

Then I think I need not trouble Your Honour with the

rest of Mr Justice Kitto's judgment. The majority
in the Federal Court took a great deal from

Mr Justice Taylor's judgment and I would wish to

submit and spend a little more time on this, that

Mr Justice Taylor is not to be understood as taking

any different view from that of the other four

members of the Court. Page 279,in the third paragraph

beginning with the word "Upon", going down six lines:

The contention is raised, however, that the word "excessive", when read in relation to an

amended assessment, is concerned only with the
amount of the assessment and, accordingly, it

is said, the sub-section does not cast upon an

appellant the onus of disproving the existence

of facts, which upon a consideration of s. 170(2),

must be regarded as a condition precedent to the

power of the colillilissioner to amend.

Then, I need not trouble Your Honours with the rest

of that and going over the page to page 280,

ClT15/l/DR 23 6/9/89
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His Honour analyses the nature of the statutory

appeal and then looks at the matter from the point of

view of common law pleadings. The word "pleadings"

appears about a quarter the way down the page:

if pleadings were necessary they would disclose

that what the appellant complains of is, not

some infringement of her personal or
proprietary rights which may or may not be

justifiable pursuant to some statutory power,

but, on the contrary, the purported exercise of

the statutory power itself which, unless denied,

will result in subjecting the taxpayer to a
monetary liability. In order to displace the

assessment the appellant in this case admits the

purported exercise of the power but denies the

existence of those facts which make the power

exercisable. I should think that in those

circumstances, and quite apart from the provisions

of the statute itself, it would be sufficiently

clear that an appellant would be bound to carry

the burden of denying the existence of those

facts.

Then, at page 281 the word "however" appears about

seven lines down on the right-hand margin:

In my view, however, "the due making of the assessment" does not involve the ascertainment

of the existence of a state of facts prescribed

as a condition precedent to the making of an

amended assessment.

Now, His Honour concludes that the fulfilment of

the conditions precedent and the ascertainment of

that fulfilment- is outside the scope of the protection

given by the section 177(1):

The process of ascertaining the existence of such

a state of facts is not in any real sense

part of the process of making the assessment and

this is the function to which the first limb of

the sub-section is precisely addressed.

I need not trouble Your Honours with the rest of

page 281.

(Continued on page 25)

ClTlS/2/DR 24 6/9/89
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MR HANDLEY (continuing): And then, going to 282, towards

the bottom of the page, about point 8 - the word

"frequently" is in the left-hand margin:

But whether or not this is so the word

"excessive" is capable of a much wider

meaning than that ascribed to it by the

appellant's argument and there is no reason

for thinking that an assessment, made in

purported but not justifiable exercise of

a statutory power, may not properly be

described as excessive; it purports to impose

a specified liability and, upon appeal, the

claim of the appellant is that he is not

liable to pay any part of it.

And going to the top of the next page, line 3:

Upon this view of s. 190(b) it may be

said that its provisions cast upon an
appellant the burden of establishing his

objections. That is to say, he is required

to establish the grounds upon which he seeks

to reduce or avoid the liability which the

assessment purports to impose upon him. But

in doing this the section requires no more
of an appellant than the nature of the relief

sought and the form of the proceeding would,

otherwise, require.

And that throws one back to His Honour's analysis

of the position on common law pleadings which I

have already read to the Court.

It is clear, in our submission, Your Honours,

that when Mr Justice Taylor was speaking of a

'purported but not justifiable exercise of a

statutory power~ he was not dealing with any

situation other than the question of the

fulfilment or otherwise of statutory conditions

precedent which all members of this Court in

McANDREW's case held was outside the protective

ambit of the expression "the due making of the

assessment".

Satisfaction of those conditions precedent

was not part of the due making of the assessment

so that it was not protected from examination on

appeal but, on the other hand, it was protected

from examination in recovery proceedings and the

appellant had the onus of proving non-fulfilment

of the conditions. Mr Justice Taylor was not

directing his mind in any way to the question of
the legal validity of the decision-making process
of the Commissioner in any case other than that

in which statutory conditions precedent were involved

C 1 T 16 /1 /ND 25 6/9/89
Dalco(2)

which lay outside the true scope of the assessment

process.

McHUGH J:  But what is the different in principle between

saying you can examine whether or not the tax should

have been raised from X to 2X by reason of

compliance with the conditions - by an examination

of the conditions necessary to make the amendment

and a case where you say the tax should not have

been 2X because certain factors were taken into

account which should not have been taken into account?

MR HANDLEY:  Because, Your Honour, apart from m:re pure questions

of statutory construction which I will not refer

to in my answer, in the second case that your

mentions where there is an attack on the decision-
making process of the Commissioner, that attack

does not go to the substantive liability of the
taxpayer - the true substantive liability of the

taxpayer, for tax. What the taxpayer is saying

is, "You went about it the wrong way; you applied

incorrect principles or you disregarded relevant
factors or you took into account irrelevant factors."

And that is all part of the assessment process

which the Act says the Appeal Court is not to be

bothered with , it is to go straight to the question ''What

is the true substantive liability of this taxpayer

to tax?".

So it treats the assessment-making process

as something - to one side. It puts it to one

side as not going to the substantive liability

of the taxpayer. And, indeed, it does not.

(Continued on page 27)

ClT16/2/ND 26 6/9/89
Dalco(2)
MR HANDLEY (continuing):  In iudicial review proceedings

the Court does not ma~e the decision. It sends it

back - except in an extreme and clear case - it

sends it back to the decision maker to do it again

and do it properly without saying what the decision

necessarily ought to be, but in the statutory appeal,

provided the materials are present, the Court's

iurisdiction is to determine the correctness of the

assessment as a fact, legally and in fact, and the
process by which the Commissioner reached that

assessment is iust swept to one side.

The appeal is an action in the original

iurisdiction of the court. It is not an appeal in

~he strict sense where you look at the way in which

the primary decision maker went about deciding the

questions before him. It is an action in the original

iurisdiction of the court in which the Court is
concerned with the true substantive liability of the

taxpayer.

McHUGH J:  Does it mean in a case like McANDREW that

McANDREW could not ultimately have succeeded unless

he showed that the amount as~essed did exceed his

actual income? Does he still ultimately bear that

burden as the bottom line?

MR HANDLEY:  He had two burdens, Your Honour. McAndrew had
two burdens:  the first was, she could succeed in

her appeal completely by showing that the conditions

precedent to an amendment under section 170(2) were

not satisfied, and that, as it were, would cut the

assessment off at its base. But the Court could

conclude that there had not been a full and true

disclosure of all material facts but then could go
on to dismiss the appeal on the merits because the

assessment was otherwise incorrect factually or

legally. It was a two-stage attack. The taxpayer

could totally succeed on either attack or totally
fail on both attacks, but the question of the

substantive liability was involved, but as the Court

made clear in McANDREW, if you showed that the power

to amend did not arise because of non-fulfilment of

the conditions precedent, you cut the amended

assessment back to zero by doing ~ust that.

DEANE J:  What if the default assessment was pursuant to

section 167(a) and the commission was mistaken in

that there had been a return?

MR HANDLEY:  Your Honour, on the appeal the question would

still be, in our submission, whether the assessment
was excessive and while the question of ignoring the

return - in my submission, GEORGE's case covers that

as a matter of authority, and on principle it is also

covered by section 177(1) - the matter would be thrown

into very clear focus in terms of the assessment of

ClT17/l/HS 27 6/9/89
Dalco(2)

the penalty for failing to make a return and
obviously in the challenge to the penalty the

taxpayer could show that he or she, or it, had

made a return and, if the return was a satisfactorv

one, that would automatically put an end to any ·

penalty tax assessed by the Commissioner.

DEANE J:  That may, though, be a mid-way position, may i~ not,

that is that one reads the sections as leaving open an attac~ to a default assessment if the conditions

precedent to power have not been fulfilled, that

is (a), (b) and (c)?

MR HANDLEY:  Yes.
DEANE J: 
But  foreclosing attack on the assessment process

once the power to assess has arisen?

(Continued on page 29)

ClT17/2/HS 28 · MR HANDLEY, QC 6/9/89
Dalco(2)

MR HANDLEY: 

Yes, Your Honour, on that view it would be an open question whether 167(a) was a condition

precedent which did not form part of the
assessment process, it being open to the view
and this Court having concluded in GEORGE's case
that 167(b) was not a condition precedent to the
exercise of the power to raise a default assessment.

BRENNAN J: 

Mr Handley, I am not sure that I follow that. I thought your argument was that section 167 was

epexegetical of section 166.
MR HANDLEY:  That is what this Court said in GEORGE's case,
Your Honour. What Mr Justice Deane was putting to

me, I think, was that there was an intermediate

position and that perhaps section 167(a) was a

condition precedent whereas (b) and (c) were not.

DEANE J:  What I was really suggesting was that there was

an intermediate position where (a), (b) and (c)

were all conditions precedent but, of course, (b)

and (c) are the sort of conditions precedent that

are very hard to attack because they are

opinion and not fact.

MR HANDLEY: 

Yes, and they are also opinions which are intimately associated with the assessment process

whereas (a) is not. But there is no doubt,
Your Honour, that section 167 is epexegetical of
section 166. I would perhaps seek to head off any
great discussion about section 167(a) by saying it
does not arise in this case and it is not likely to
be a major problem but in the end the onus would
still be on the taxpayer of showing that if
section 167(a) was a condition precedent that it
was not fulfilled and of showing that the
assessment was excessive.  I would, I think, thinking
on my feet, take the ultimate position, Your Honour,
that section 167(a) is not a condition precedent
to the validity of an assessment under sections 166
and 167. If the Corrnnissioner has made an
administrative error in failing to pick up a return,
that really does not go to the excessiveness of
the resulting assessment.  He may have got his
assessment right and he may have under assessed,
in fac~ because the return may disclose more income.

The only issue on the appeal is, is the

assessment excessive and that involves a comparison

between the amount assessed and the true figure

and you would not displace the assessment by

showing that the taxpayer had made a return. It is

not the sort of condition precedent that we have

i~ section 170(2) where if you show that the power

has not arisen you displace the amended assessment

entirely. Here, by showing that the taxpayer had

ClT18/l/JH 29 6/9/89
Dalco(2)

made a return, in fact, you would not go anywhere

towards displacing the assessment. I mean,

GEORGE's case is, of course, clear authority that

section 167(b) is not a statutory condition

precedent.

Your Honours, I would seek now to go, if I

may, to BLOEMAN, 147 CLR 360, a more recent

decision of this Court.

(Continued on page 31)

ClT18/2/JH 30 6/9/89
Dalco(2)
MR HANDLEY (continuing):  I will not trouble Your Honours
with the headnote, I wish to say this about

the facts: that in that case the taxpayers sought,

within the confines of the statutory appeal, to

undertake an attack on the assessment by way of

judicial review and page 361, at about point 6, the
last couple of lines of the long paragraph:

In a summons for directions in the appeal the company sought declarations in the

following terms:

1.      A declaration that both the original and

amended assessments ..... were void and of

no effect in law in that:-

(a) they did not nor did either of them issue pursuant to and their issuance was not authorized by s.166 and/or

s .174 .....

(b) they did not nor did either of them issue as a result of a bona fide exercise of the powers vested in the
defendant pursuant to s.166 and/or
s.174;
(c) each of them issued other than as a
result of a bona fide exercise of
the powers vested in the defendant in

an attempt inter alia to place the

defendant in a position; Ci) to
support the issue of -

garnishee -

notices -

under -

s.218; (ii) to harass the plaintiff;

(d) they were not nor was either of them
an assessment within the meaning of
the Act.

And there was an attack, as I say, on the validity,

as opposed to the correctness of the assessments on

those general grounds. In the middle of page 362:

On the hearing of that summons the question

arose whether the Court had jurisdiction to

entertain the submissions in the context of a

statutory appeal. The company then filed an

originating summons in the general jurisdiction

of the Supreme Court for the same declarations.

This was before the AD (JR) ACT, of course and:
CIT19/l/CM 31 6/9/89
Daleo ( 2)

By consent both summonses were heard together.

So that there was an attack on the legal validity of

the assessments by reason of what had taken place

in the assessment process by way of exercise of

statutory power, within the confines of the

statutory appeal and within the general jurisdiction

of the s:.1preme Cburt. The joint judgment of

Mr Justice Mason and Mr Justice Wilson was in fact

concurred in by Mr Justice Stephen and

Mr Justice Aickin and represented the clear majority

view in the Court. Can I go to page 371 in the

joint judgment. The new paragraph on the page

about eight lines down, says:

The argument turned very largely -

that is the argument of the appellants. Then

Their Honours refer to particular sections and

I can pass over those. And going down to eight
lines from the bottom: 

The word "assessment" is defined in s.6 to mean,

unless the contrary intention appears, the
ascertainment of the amount of taxable income

and of the tax payable thereon. In

BATAGOL V FEDERAL COMMISSIONER OF TAXATION,

the Court considered the meaning of "assessment''
in the context of s.170 and the group of sections

with which it is associated. Kitto J. observed

"Assessment- in the sens-e of mere calculation

produces no legal effect. No step that the

Conmissioner may take, even to the point of satisfying himself of the amount of the taxable income and of the tax thereon, has under the

Act any legal significance", until he serves

a notice of assessment. Then and then only has
an "ascertainment" been made. The amounts of

taxable income and tax are then rendered certain.

(Continued on page 33)
CIT19/2/CM 32 6/9/89
Dalco(2)

MR HANDLEY (continuing): That is the meaning of the word "ascertain" and that is the meaning of the word

"assessment" and so when we come to section 19O(b),

despite slightly inappropriate language, one

finishes up with a view that the onus is on the

taxpayer appellant of showing that the amount of

taxable income and tax are excessive.

In this context, according to his Honour

"assessment" means "the completion of the
process by which the provisions of the Act
relating to liability to tax are given

concrete application in a particular case

with the consequence that a specified amount

of money will become due and payable as the

proper tax in that case."

Other members of the Court agreed.

BATAGOL supports the view that the

process of assessment is completed when the
Commissioner inserts in the notice of assessment
which is served on the taxpayer the amount
of his taxable income and the amount of tax

payable there. There is nothing in BATAGOL

to suggest that the court will go behind the

assessment of a taxpayer's taxable income

and tax payable as expressed in the notice

of assessment served on him, unless it

appears from the notice or an accompanying

document that the notice is not in truth a

notice of assessment.

And then we can turn to 373. There is a reference

at the start of the second paragraph on that page

to GEORGE and McANDREW and, going down a few lines,

there is a reference to 17.7(1):

The d i s t inc t ion d r awn by s . 1 7 7 ( 1) i s be tween

the procedure b¥ which the taxable income

is ascertained (the "due making" of the

notice of assessment is conclusive evidence)
assessment of which the production of the
and the taxpayer's substantive liability to
tax -
Reference is made to GEORGE's case. And then an

analysis of McANDREW is commenced in the joint

judgment.

In McANDREW, Dixon CJ, McTiernan and

Webb JJ, noted that, although the existence

of conditions giving rise to the exercise of the power to amend an assessment might

be thought otherwise to be part of the "due

making" of an assessment, the consequence

of this interpretation would be to deny to

C 1T2O/l /ND 33 6/9/89
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the taxpayer the right to challenge

the exercise of the power.

And, hence, the Court strained to find that they

were not covered by the due making of the assessment.

And going over to the next page, 374, at the

end of the first long paragraph, about seven lines

up - the word "tax" appears in the left-hand margin:

There is no like reason for reading the

sub-section so as to allow the taxpayer to

context the making of an original assessment,

when a notice of assessment has been served,

and the making of that assessment is not

similarly conditioned -

that is, like the amended assessment was conditioned

by 170(2) -

the taxpayer being entitled to contest his
substantive liability to tax in Pt V proceedings,
without contesting the making of the initial

assessment.

In other words, the interpretation which lay behind

McANDREW's case was one in which the Court sought to avoid two extreme positions in favour of either the taxpayer or the revenue but there is no such imperative when one comes to the rest of the Act.

And then, at 375, Their Honours refer to

Mr Justice Taylor's judgment in McANDREW:

An explicit and, in our view, correct

statement of the effect of s. 177(1) was made

by Taylor Jin McANDREW. For the reasons

there expressed his Honour concluded that

"s.177(1) was intended to make it impossible

for a taxpayer, in proceedings other than

appeal against it, to challenge an assessment

on any ground". He conceded that the word
"excessive" in s. 190(b) was inappropriate.
However, he considered that an assessment
"made in purported but not justifiable exercise
of a statutory power" could properly be
described as "excessive".

With ~ery great respect, Mr Justice Taylor, of course,
had also said that in the process the taxpayer was showing
that he did not owe any part of the tax the subject of the
amended assessment. So there one gets a reconciliation of

the notion of the word "excessive". This is at the bottom

of page 282. Mr Justice Taylor said - it is part of the

passage referred to by Their Honours:

Upon appeal, the.claim of the appellant is that he

is not liable to pay any part of it.

ClT20/2/ND 34 6/9/89
Dalco(2)
MR HANDLEY (continuing): 

This interpretation gives expression to the

policy which underlies, and is manifest in,
the statutory provisions. The effect of this

policy is that, once the Commissioner takes

advantage of S. 177(1) by producing an

appropriate document, the taxpayer is precluded

from contesting that the Commissioner has made an assessment or that in making the assessment he has complied with the statutory formalities.

The taxpayer is entitled to dispute his

substantive liability to tax in proceedings

under Pt V.

Although s. 190(b) places the onus on a taxpayer .....

it enables him to contest his substantive liability

to tax.

Then at page 377, at the very top of the page line 2 -

referring to section 177(1):

Although the sub-section is evidentiary and begins to operate when an appropriate document

is produced in a court or board of review,

and not before, its effect is to put the making

of an assessment beyond challenge.

And then after reference to what fell from the

Chief Justice in BAILEY:

The Commissioner may be right or wrong in his view of the facts, but it would appear to be

incontrovertible that the figure on the notice of assessment which records the Commissioner's

view of the taxable income evidences that a
process of assessment was actually undertaken

however cursory or inadequate that process

may have been.

Reference is made to GEORGE's case and then a

reference is made to TRAUTWEIN to which I will take
the Court:
In our opinion, it must follow that a notice
in proper form of an assessment necessarily
compels the conclusion that there was an
assessment made in fact.

Then further down in the middle of that page, talking

about the "Bloemen notice of assessment", going to

the last four lines of that paragraph:

Its production will put beyond contention the

due making of the assessment so that the Court
ce.nnot find that no assessment was made or that,

if made, it was made for an inadmissible purpose.

ClT21/l/DR 35 6/9/89
Dalco(2)

Your Honours, it is our respectful submission,

that the combined effect of those three ·cases- is to totally

undermine the majority view in the Federal Court

and totally support the view of Mr Justice Wilcox.

I would seek to conclude our submissions by reminding

Your Honours, first of all, of an earlier dispute

in this Court as to the effect of the onus provisions.

I can do that very briefly because Mr Justice Mason's
judgment in GAUCI, although a dissenting judgment,

it was later reinstated by Full Court decisions.

If I could go to GAUCI at 135 CLR 81. This

was a section 26(a) case and what the trial judge

had done, in the Supreme Court of Western Australia,

was to decline to accept the taxpayer's evidence as

to the purposes which actuated them when they bought

the land. Nevertheless, the majority of this Court
allowed an appeal from the decision confirming the

assessment over the dissent of Mr Justice Mason, as

he then was.

Going to Mr Justice Mason's judgment at page 88,

at the start of the last paragraph:

The judge declined to accept the appellant's evidence as to their intentions in purchasing the land and the evidence of the land agent Graham

who acted for them.

Going to the top of page 89, line 4:

These findings must be accepted as correct,

involving as they did, an assessment of the

appellants' credibility. They constitute a

defect in the appellants' case which is in my

view fatal to their success.

(Continued on page 37)

ClT21/2/DR 36 6/9/89
Dalco(2)
MR HANDLEY (continuing): 

Section 190(b) of the Act imposed on the appellants the burden of proving

that the assessments were excessive. The

appellants relied on their evidence and

that of Graham in order to show that the

assessments were excessive. Once that evidence was rejected, the appellants'

case necessarily failed.

Making all allowances for the different facts in

the two cases, in our submission, once Mr Dalco's

evidence was rejected, in our submission, his

case necessarily failed.

The Act does not p-la.ce- any onus on the

Commissioner to show that the assessments were

correctly made. Nor is there any statutory

requirement that the assessments should be

sustained or supported by evidence. The

implication of such a requirement would be

inconsistent with S. 190(b) for it is a
consequence of that provision that unless the

appellant shows by evidence that the assessment

is incorrect, it will prevail.

And, at the very bottom of page 89, the last three

lines:

The crux of the matter is that when in

as. 26(a) case an appellant seeks to overcome

the onus created bys. 190(b) by adducing

evidence as to his intentions with a vew to

establishing the purpose of the acquisition

was not as. 26(a) purpose and that evidence

is not accepted, he has not discharged the

onus which he bears. At best, from the

appellant's viewpoint, the evidence stands

in a situation in which it is equivocal, neither

establishing a S. 26(a) purpose nor denying the

existence of such a purpose. At worst, the judge may, in the circumstances, be able to
infer the existence of as. 26(a) purpose.

In either event the appellant fails to discharge the onus and his appeal fails.

Now, that minority view was, as I said, later upheld

by the Full Court of this Court, and I merely

give Your Honours the references to McCORMACK V

THE FEDERAL COMMISSIONER OF TAXATION, 143 CLR 284, and

MACMINE V THE FEDERAL COMMISSIONER, reported not in

the CLR, but reported only in the other reports,

53 ALJR 362.

ClT22/l/FK 37 6/9/89
Dalco(2)

What, in our submission, is demonstrated by GAUCI's case, apart from a, with respect, correct

view of the "onus" section, is that the first

task of a taxpayer on a Part V appeal is to

establish the relevant facts. It is possible that

the only dispute between the parties is a dispute as to the Jaw: the facts are agreed and the matter proceeds as a question of law. But, if the facts

are not agreed, the taxpayer's first step is to

establish what the relevant facts are, and if he

fails at that point, that is the end of the case.

And, to be able to say, "On other possible views of

the facts, the Commissioner made errors of law", is

just beside the point; it is an academic exercise,

in our submission.

We would seek to conclude our submissions by

taking Your Honours back to TRAUTWEIN V THE COMMISSIONER

back in 56 CLR, because it is our respectful submission

that much of this ground was, in fact, necessarily

traversed all those years ago in TRAUTWEIN under the old

Act. 56 CLR 63, and it is convenient - I will not

worry Your Honours with the headnote - there were a

number of proceedings before the Full Court, one of

which was a case stated by Mr Justice Evatt, who had

heard appeals in the original jurisdiction of this

Court against tax assessments raised against Mr Trautwein,

and the facts stated by Mr Justice Evatt are

summarized - or quoted from the stated case, at page 78,

and the Commissioner's assessment process is there

exposed, as applied to Mr Trautwein:

In taking such report as a basis -

top of the page -

the commissioner proceeded in the following

manner. He determined the amount of the

assets of the appellant as at 1st July 1920

and then determined the amount of such assets

as at 30th June 1927. The amount of assets

as at the latter date exceeded the amount

as at the former date. Part of the amount of
such excess consisted of assessable income of the
appellant derived at some time or other during
the income years 1921 to 1927 inclusive.

(Continued on page 39)

C1T22/2/FK 38 6/9/89
Dalco(2)

:MR HANDLEY (continuing):

The commissioner did not ascertain how much of such part of the excess was

derived by the appellant in each of

such years. He divided the total

amount of such part equally between the

seven years under review by him and

then added such seventh to the assessable

income of each of the seven years which

for the purpose of his assessments he

treated as already ascertained. The

various amounts of the assessable income

so treated as already ascertained, were

unequal.

From the materials and information in his possession at the time of the

assessments made by him in November 1931

it was not possible for the commissioner to
allocate to each of the seven income

years in question its precise proportion

of the relevant accretion. But it was

possible for the commissioner in respect of each one of such seven years to adopt

the course of comparing the assets of the

appellant as at the beginning and as at

the end of each income year. Owing to the

failure of the appellant to keep proper

books and accounts the latter course would

have entailed considerable labour and

expense. The commissioner could not have

ascertained the assessable income for each

year from the returns and other information
and answers to requests furnished to him
by the appellant.

That part of the amount of the accretion of assets which was due to income

earnings of the appellant was derived, not

equally but unequally, over the period of

the seven relevant income years. But the
appellant has failed to prove during what
years that part of the accretion
representing income was earned and as a
consequence has failed to establish
affirmatively at what figure the income
assessed against him in respect of each of
the seven years should be assessed. Thus
the amount of taxable income contained in
each of the seven assessments under the
method adopted by the commissioner is in
fact incorrect and one or more must
necessarily be excessive but the appellant
has failed to establish affirmatively what is
the precise amount of taxable income in each year.
ClT23/l/JH 39 6/9/89
Dalco(2)

And, Mr Justice Evatt asked the Full Court

whether, in the light of those findings, he should

allow the taxpayer's appeal or dismiss it and the

Full Court held unanimously the appeals should be

dismissed. Going to page 87, in the middle of the

page, the long paragraph concerns the then

relevant statutory provisions and some discussion

of earlier cases and I pass over that. Going to
the last paragraph: 

In the absence of some record in the mind

or in the books of the taxpayer, it would

often be quite impossible to make a

correct assessment. The assessment would

necessarily be a guess to some extent, and

almost certainly inaccurate in fact.

There is every reason to assume that the

legislature did not intend to confer upon

a potential taxpayer the valuable

privilege of disqualifying himself in

that capacity by the simple and relatively

unskilled method of losing either his

memory or his books.

Over the page:

The application of section 39 is not, in

my opinion, excluded as soon as it is shown
that an element in the assessment is a

guess and that it is therefore very

probably wrong. It is prima facie right -

and remains right until the appellant shows

that it is wrong. If it were necessary to

decide the point I would, as at present

advised, be prepared to hold that the

taxpayer must, at least as a general rule,

go further and show, not only negatively

that the assessment is wrong, but also

positively what correction should be made

in order to make it right or more nearly

right. I say "as a general rule" because,
conceivably, there might be a case where
it appeared that the assessment had been
made upon no intelligible basis even as an
approximation, and the court would then set
aside the assessment and remit it to the
commissioner for further consideration.

And then, going to page 89, His Honour there sets
out section 36 which was the equivalent in the

earlier legislation of section 167 in the present Act.

But, it contained its own onus provision built in

which was not in the general provisions of the Act

and if Your Honours go to the last couple of lines of

section 136, one sees:

ClT23/2/JH 40 6/9/89
Dalco(2)

the person assessed shall be liable

to income tax thereon, excepting

so far as he establishes on objection

that the assessment is excessive.

So, the assessments against Mr Trautwein were

section 36 amended assessments and so although the

general provisions of the Act at that time did not
put on the taxpayer the onus of establishing that
his assessment was excessive, that onus was placed

on him in terms by section 36 in relation to

amended assessments.

(Continued on page 42)

ClT23/3/JH 41 6/9/89
Dalco(2)
MR HANDLEY (continuing):  We then go to page 92, at the top

of the page, the Chief Justice said:

Thus, in my opinion, both sec. 39 and
sec. 36 apply to this case. If so,
the taxpayer is liable to pay tax upon

the amount stated in the assessment as

that upon which income tax ought to be

levied, unless he displaces the prima
facie presumption created by sec. 39.

Further, sec. 36 imposes the same liability excepting in so far as he

establishes on objection that the

assessment is excessive .....

It is at leasts clear that sec. 39

places upon the taxpayer the burden of

showing in relation to a particular year

under consideration, say 1921, that the

amount or some of the particulars of the

assessment are incorrect and that their
incorrectness operates to his preiudice.

The same question arises separately in

relation to each year. Most probably all

the estimates of the income of the taxpayer

are wrong, some in his favour, some against

him. But has the taxpayer shown that he is

prejudiced in relation to any particular year?

In my opinion he has not. Of course the

chances are that each particular year is

wrong, but,if each year is taken by itself,

all that the taxpayer has shown is that the

method adopted by the commissioner is such

that it is very unlikely that he has reached

an accurate result. He has not shown

positively that the total amount, or that any

~articular item going to make up that amount,

1s wrong.

Then on page 93, just a few lines opposite the

reference to the Chief Justice's name in the margin:

The assessment for a particular year may
or may not be so excessive. Upon the facts
stated no one can say whether it is or not.
The result of the statutory provision is
that, as the taxpayer has not established,
in respect of any year, that the assessment
is excessive, he is liable (upon the basis
of the facts stated, i.e., no more appearing
than those facts) to pay tax upon the
assessment for each year.

Then going to page 98, paragraph 10:

The court is asked in question 4 of the

case whether the assessments are invalid

by reason of the method adopted by the

comm1ss1oner -

Cl T24/l /HS 42 6/9/89
Dalco(2)
fl fl
"invalid", not excessive -

by reason of the method adopted by the

commissioner in distributing equally

between the seven years 1921 to 1927

the income which cannot be accurately

apportioned. The assessments in question

against which the appeals are brought are

amended assessments. There is nothing in the case stated which shows that they were not validly made ..... It was, indeed, urged that

the method adopted by the commissioner in

arriving at his figures, the results of

which are described in par. 24 of the case ..... was such as necessarily to invalidate

the assessments. This, however, appears to

me to be plainly a matter of the correctness

and not of the validity of the assessments.

So the taxpayer's appeals failed. Mr Justice Star~e,

at page 103 iust one line below the reference to his

name in the margin:

The amount of taxable income contained in

each of the seven assessments under the method

adopted by the commissioner is necessarily

incorrect, but the taxpayer cannot establish

the precise amount of taxable income in any

year.

In the joint judgment of Mr Justice Dixon and

Mr Justice Evatt at page 111 and page 112 -there 1s a reference at the top of page 111 to section 37

just inside the left-hand margin about 10 lines down:

In our opinion the title of the taxpayer to be relieved against any of the assessments depends upon the question whether it is incumbent upon him to show no more than that the assessment is erroneous, or, on the other hand, to show

amount. If sec. 36 provides machinery which
that it should be reduced by some ascertained
may be availed of under sec. 37, it would,
we think, result in imposing upon the
taxpayer the burden of showing that the
assessment should be reduced by some figure.
For he is to be bound -

by the assessment -

excepting so far as he establishes on

obiection that the assessment is excessive.

But in any case the Act throws upon the

taxpayer the burden of obiecting to and

appealing .....

ClT24/2/HS 43 6/9/89
Dalco(2)

MR HANDLEY (continuing):

The burden lies upon him in the judicial

proceedings which he is thus required to take of establishing that the assessment

or amendment imposes upon him a liability

to which the taxing provisions of the Act do not subject him. Within the limits of

his objection he must show that the assessment

is contrary to law or to fact. If so much

is established, the court may set aside the

assessment and remit it for reconsideration,

or may itself determine the amount of the

liability. But error or law or fact

affecting the particular assessment must

appear .....

In respect of no one of the seven years

can it be correctly said that the taxpayer

has shown that the amount allocated thereto

from his aggregate gains of the seven years

exceeds that which was derived therein.

It is not enough for him to prove that in

one or more out of the seven this must be

so without identifying which it is. He does

not show that he has been prejudiced by any

departure from legal standards and he does

not show that the facts assumed in any
particular year are not true of that year.

Your Honours, Chief Justice Latham said - and I have already read the passage at the bottom

of page 87 - that the provisions reflected a view

that Parliament did not intend to allow taxpayers

to opt out of the tax system by the simple and

unskilled method of losing either his memory or

his books. If one were to update that to the

contemporary scene one would have to add something

to this effect, "By surrounding himself or herself
with a multiplicity of legal entities, trusts or
partnerships and then either failing to keep any

or any proper books or else losing his memory or

those books".

The problem here is, in this case before the Court, simply an updated version of the problem

which this Court faced and solved in TRAUTWEIN

and, in our submission, making allowances for the

different facts of the two cases, a taxpayer cannot

merely by pointing to a multiplicity of different

entities surrounding him and his business affairs,

in effect, prevent the Commissioner from assessing

him to income tax on his apparent life style and
cannot discharge the onus of proof in appeal
proceedings by pointing to the confusion with which

he has surrounded his affairs and saying that the

44- 6/9/89

Dalco(2)

Commissioner has applied an inadmissible approach

when he has completely failed to face head-on the

onus and the assessments and to prove what his

true income was.

So for those reasons, if the Court pleases,

we would submit the appeal should be allowed.

MASON CJ: Thank you, Mr Handley. Yes, Mr Jackson.

MR JACKSON: 

Your Honours, may I hand to the Court copies of our outline of submissions and also copies of

a typed document which sets out the relevant
sections of the Act.  Some are not covered in my
learned friend's extract.
MASON CJ:  Thank you.
MR JACKSON:  Your Honours, may I, before turning to our

submissions, say this first: this is a case where

the respondent was assessed over four years with

large sums of money being the taxable income.

The basis of those assessment was made clear.
The majority in the Full Court held that there

was nothing in the basis in respect of any one
of those years adopted by the Commissioner when

making the assessments and the correctness of the

majorities taking that view is not now in issue.

So that there remained, however, large assessments

in exact sums for which it was shown there was
no basis.

Your Honours, the issue then was whether those assessments should yet stand because the respondent

had not proved what his actual income was or whether -

and in this respect the observations made in the

last passage referred to in TRAUTWEIN's case will

be relevant and I will come to that in a moment -

the case should, as the majority in the Full Court
said, there having been shown to be an error in

the assessment then go back to the Commissioner

for reassessment. (Continued on page 46)
ClT25/2/ND 45 6/9/89
Dalco(2)
MR JACKSON (continuing):  Now Your Honours, having said that,

could I come first to section 190 which is, in a

sense, the commencing point. May I say something

about it before going to its terms, and that is

that section 190 has played a very large part in
the argument on behalf of the appellant, but one

should observe, in passing, that section 190 is

not the provision which itself confers a right to

appeal or con£ ers jurisdiction upon the court or

a tribunal to hear such an appeal or review.

What it does do is to regulate the issues which may

be agitated on the hearing of an appeal and also to

determine, in relation to those issues, who bears

the onus of proof.

Your Honours, the point of saying that is simply

that one should bear in mind the place which

section 190 occupies. It is a section which takes

its place together with other sections in relation

to the assessment and objection and review provisions,

but it is not the provision which itself is dominant.

Your Honours, it provides, if I could go to its

terms now, that on an appeal to a court two features

have to be borne in mind. And, Your Honours,I have

limited myself to an appeal to the Court for the

moment. Two features have to be borne in mind.

One is that:

the taxpayer shall be limited to -

what is described in section 190 as being -

the grounds stated in his objection;

Your Honours I will return to that, if I may. The
other is that in those ·p-ro·ceedings -it is
the taxpayer who bears -

the burden of proving that the assessment is

excessive.

And Your Honours, those provisions in section 190

are the concluding provisions of a series designed

to result, in our submission, in there being defined

issues before the Court on the hearing of an appeal.

Your Honours, some guidance as to the nature as to

the proceedings in contemplation in an appeal. is to
be found, in our submission, from the two concepts

mentioned specifically in section 190, that is

objection and assessment. And Your Honours, may I

deal first with assessment and follow that through

and in the course of it deal with the other concept,

that of objection?

CIT26/l/CM 46 6/9/89
Dalco(2)

Your Honours, in relation to assessment, one goes

first to section 166 which provides that:

the Cormnissioner shall make an assessment

of the amount of the taxable income of any

taxpayer, and of the tax payable thereon.

Now Your Honours, the term "taxable income 1' is

defined to mean in section 6:

"the amount remaining after deducting from the assessable income all allowable deductions" -

Your Honours, I suspect that that definition is not

included in those extracted passages. Can I give

Your Honours, after lunch, one or two passages from

the definition section of the Act also. But simply,

section 6 says 11 that it is the amount remaining

after deducting from the assessable income all

allowable deductions". So that the term "taxable

income", used in section 166, is the result of a

calculation, namely a subtraction of what is contemplated

by allowable deductions from what is contemplated by

assessable income, both those terms themselves being

defined by section 6 as meaning respectively the

amounts which are assessable income as provided for

by the Act or allowable deductions as provided for

by the Act.

But Your Honours, if one could pause at that

point in relation to section 166, the disputes which

might arise between the Cormnissioner and a taxpayer
must relate to, leaving aside questions such as the
appropriate rate of tax, if that were an issue in
particular circumstances, must relate to such matters

as whether the taxpayer derived income in a year;

whether that income is assessable income, and if so,

to what extent; and whether the taxpayer has an

entitlement to an allowable deduction and if so, its

amount.

(Continued on page 48)
CIT26/2/CM 47 6/9/89
Dalco(2)
MR JACKSON (continuing):  Your Honours, I have expressed

that broadly but within those various headings
there are, no doubt, discrete items which might

fall for consideration; for example, whether

a particular sum is an allowable deduction or

whether a particular amount is something which is

to be taken into account as being assessable

income.

Your Honours, if I could pause there in

relation to section 166 and move on to section 167,

Your Honours will see that section 167 is somewhat

differently expressed because what it says in its

concluding words is that:

the Conrrnissioner may make an assessment
of the amount upon which in his

judgment income tax ought to be levied,

and that amount shall be the taxable

income of that person for the purpose of

section 166.

Your Honours, although the concluding words of the

section are differently expressed, the task upon

which the Conrrnissioner is engaged under section 167

is once again to arrive at taxable income by

recourse to the Act rather than, of course, by

recourse to whim. And, Your Honours, that that is

so appears from two things; the first is that as

the Court said in GEORGE V FEDERAL COMMISSIONER OF

TAXATION, 86 CLR 183 at 203-204, Your Honours in

particular at the bottom of page 203, a passage to

which my learned friend has referred; at the

bottom of page 203 to the top of page 204, the

Court there said that:

Sections 166 and section 167 do not

prescribe distinct duties or functions.

They combine to show what the conrrnissioner

may or must do in performing his -

in the end - single duty of arriving at an assessment.

And, of course, members of the Court used the expression that:

Section 167 is epexegetical to

section 166. It is not an independent

power.

Your Honours, that is the first matter in the

sense that what is being done under section 167 is to arrive at the same thing - if I can put it that

ClT27/l/JH 48 6/9/89
Dalco(2)

way - as is contemplated by section 166; that is,

to arrive at taxable income.

McHUGH J: 

But, Mr Jackson, there must be some cases where, on any

view,

the Corrrrnissioner can,

in effect, just pluck a figure out of the air.

Take the case of a prostitute. All he knows is

that somebody is a prostitute and has not got the

faintest idea of what hours or what she does at all.

Why cannot he say, "I will assess her at $50,000"?

MR JACKSON:  Yes, Your Honour, I really was not intending
to convey otherwise, with respect. What I was

simply seeking to do at this point was to say that

what he has to arrive at is what he regards as

being her taxable income and taxable income being

the amount for whic~ if there had been a return or

so on, she would be liable as taxable income. Now,
it may be that in some cases the method of
arriving at the taxable income is one which the

Corrrrnissioner adopts under section 167 does involve a comparison of gross earnings, if I could put it

simply, with likely allowable deductions. It may be

that it is simply based on what people in

comparable situations seem to have as

taxable income and it is not necessary for him in

every case to go through the process of calculation.

The point I am seeking to make about it, Your Honour,

is that what he is trying to arrive at is the same

amount as he would have arrived at under section 166

and it is the same concept; the method of doing it
might be slightly different depending on the

circumstances.

Your Honours, I was just going to say one other

thing about section 167. That it involves the notion that the amount to be arrived at is the

amount of taxable income is made apparent - is the
real amount of taxable income, if I can put it

that way - Your Honours, is made apparent by the

use in it of the word "assessment", a term which

itself means, as Your Honours will see in the

definition of that term, the ascertainment of the

amount of taxable income and the tax payable on it.

(Continued on page 50)

C1T27/2/JH 49 6/9/89
Dalco(2)
MR JACKSON (continuing):  Your Honours, there are observations

to that effect also in GEORGE V FEDERAL COMMISSIONER

OF TAXATION at page 204. Your Honours, that appears

in about 10 lines from the top of the page on

page 204:

By definition "assessment" means the ascertainment

of the amount of the taxable income, and of the

tax payable thereon.

And so on. Your Honours, the concept of assessment

was dealt with, or what is meant by "assessment", and

Your Honours I am sorry to labour the point a little

but what I am simply seeking to do is to indicate that
when one is speaking about the assessment in terms

of section 190, in the end what is being spoken about

is something which is or may be a calculation and it

involves a number of steps. That is, it is a concept
involving what is the amount of taxable income as

distinct from a mere sum.

Your Honours, what is meant by the concept appears from references Your Honours have already been

given, I think, BATAGOL V COMMISSION OF TAXATION,

(1963) 109 CLR 243 at pages251-252 and page 257 and

also the passage in the judgment of Your Honour the

Chief Justice and Justice Wilson in

F.J. BLOEMEN PTY LIMITED V FEDERAL COMMISSIONER OF

TAXATION, (1981) 147 CLR 360 at 371-372.

TOOHEY J:  Mr Jackson, what is the difference between the

situations envisaged by paragraph (a) and (c) of

section 167?

MR JACKSON:  I have some difficulty, Your Honour, in seeing
a great· diffe-renee be-tween them,.. f>ne- can understand a

degree of emphasis being involved in the expression

"default" in paragraph (a) where one would think

that, perhaps, it means that a person who knows that

he should, has not done so and, perhaps, in paragraph (c)

that element is not present. But, Your Honour, subject

to that there does not seem to be a great difference

between them.
TOOHEY J:  It may have some relevance to the connection between

section 166 and 167. For instance, in relation to

(c) there is an assumption that the Connnissioner has

some information which leads him to believe that a

person who has not furnished a return has derived

taxable income. In that event section 166, or in

that situation, I suppose, section 166 would provide

a sufficient authority of itself. If there was a

default in furnishing a return and the Connnissioner

had no information in terms of section 166 it might

suggest that section 167 was some independent

authority for making an assessment.

ClT28/l/DR 50 6/9/89
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MR JACKSON:  Yes, Your Honour, I suppose it is possible that

there is an area not covered by section 166 that is

covered by section 167 but - - -

TOOHEY J:  It would be a fairly unusual situation where there

was not only no return but no information in the

possession of the Commissioner from which he could

even begin to make an assessment.

MR JACKSON:  Yes, well, Your Honour, the situation which would

then arise, one would think, would be that as soon as

he started to examine the matter one would think that

very•quickly he would become in possession of some

information.

TOOHEY J: Yes, well, one would expect so, that is why I say

it would have to be an unusual situation but I suppose

it is at least conceivable that there could be a

situation where there was no assessment and all he

knew was the name of an individual and knew nothing

about that individual.

MR JACKSON:  Yes.

TOOHEY J: Although I suppose you would say some inquiry would

then be made and you would end up with some information,

one would expect, from which he could make an

assessment.

(Continued on page 52)

ClT28/2/DR 51 6/9/89
Dalco(2)
MR JACKSON:  Yes. Your Honour, probably, if one just looks

at the difference between (a) and (c), (a) probably

is designed to take care, at least, primarily of the

case where some one deliberately does not file a

return. (c) may well be there to cover a wider

range of cases, but also to take care of cases where

people really might not know they have to file a

return, in a sense, might not be aware of it, for

example, young people working for a short period

might not be aware of a need to file a return, and

things of that nature.

TOOHEY J:  But that would still constitute a default, would it
not?

MR JACKSON: Well, Your Honour, it would in one sense, but it

just depends what is meant by "default" in that

sense.

TOOHEY J:  You think it might have some pejorative overtones.

MR JACKSON: It may have, Your Honour, yes. In that sense

perhaps (a), (b) and (c) seem to be in descending

order of fault, if I can put it that way.

Your Honours, once the assessment is made,

notice of it is required to be served under determination of taxable income referred to in the
section 174(1), and, Your Honours, it is the service
of the notice which imposes restrictions upon the
ambit of the rights of both the taxpayer and the

notice of assessment. Your Honours, the restrictions

on the taxpayer, if I can deal with those first,

commence with section 177(1) which provides that:

The production of a notice of assessment .....

shall be -

on the one hand -

conclusive evidence of the due making
of the assessment and -

on the other hand -

(except in proceedings on appeal against

the assessment) that the amount and all

the particulars of the assessment are correct.

And, Your Honours, I wonder if I could refer
Your Honours for just a moment to F.J. BLOEMEN PTY LTD

V FEDERAL COMMISSIONER OF TAXATION, 14 7 CLR 360, at page 375

where, in the joint judgment of Your Honour the

Chief Justice and Justice Wilson, the effect of these

provisions was referred to and, Your Honours, it

ClT29/l/FK 52 6/9/89
Dalco(2)

is in the first two paragraphs on page 375,

to which Your Honours have already been referred,

and Your Honours will see there, in the second

paragraph, the statement of the policy that the

taxpayer, once section 177(1) is used is:

precluded from contesting that the

Commissioner has made an assessment or

that in making the assessment he has

complied with the statutory formalities.

The taxpayer is entitled to dispute his

substantive liability to tax in proceedings

under Pt V.

And Your Honours went on to say:

Although s. 190(b) places the onus on a taxpayer upon a reference or appeal of proving that the assessment is excessive,

it enables him to contest his substantive

liability to tax. It is then for the

board upon a reference or the court on an

appeal, within the framework of the

taxpayer's objection -

that is a matter to which I will come -

to ascertain whether he is liable to tax

and, if so, in what amount.

And, Your Honours go on to mention the protection given

by the Part V procedures. Your Honours, that is the
first restriction, section 177(1). The second

restriction is that embodied in section 185, namely

that whilst the taxpayer,dissatisfied with an

assessment - he is given a right to object to an

assessment - the objection must itself state fully

and in detail the ground, or grounds, upon which the

objecting taxpayer relies. Your Honours will see that
set out in section 185.

(Continued on page 54)

C1T29/2/FK 53 6/9/89
Dalco(2)

MR JACKSON (continuing): And, Your Honours, in relation

to amended assessments, Your Honours will see in

subsection (2) that there is again a further

restriction on the right to object.

Your Honours, the objection contemplated by

section 185(1) is an objection in writing against

the assessment and in relation to that assessment

the objection has to state fully and in detail

the grounds which are relied on as an objection

against that assessment. And, Your Honours, those

expressionsmilitate, in our submission, against

the contention that it really does not matter very

much how the Commissioner arrives at the amount

of taxable income because what one is looking at

in the end is whether it has been established that

the overall amount is wrong.

Your Honours, if I could go back for just a moment to section 177(1), a somewhat similar

notion is conveyed by the concluding words of

section 177(1) because the effect of the words

"except in proceedings on appeal against the

assessment" means that one would think that

subsection (1) is contemplating that a matter that

may be the subject of review on the assessment
or may be the subject of evidence is not just the
amount but as section 177(1) says, the particulars
of the assessment, that is the correctness of

the particulars of the assessment, as distinct

from just the amount.

Your Honours, if I could go back to the

objections. Once the objection has been lodged,

the Commissioner is obliged by section 186 to
consider it and to either disallow the objection

or allow it in whole or in part and, Your Honours,

that is stated specifically by section 186(1).

And the Court's decision in TRAUTWEIN V THE

COMMISSIONER OF TAXATION, (1936) 56 CLR 63, in

two passages referred to the fact that the

Commissioner's decision on objections must be

explicitly stated. Could I take Your Honours to page 96. And

at the bottom of page 96, in the last paragraph

on that page, the Chief Justice said, in the

fourth line:

Under sec. 50 the taxpayer is entitled to

a clear decision upon each separate objection.

The commissioner, in his decision, should

either disallow an objection, or allow it,

either wholly or in part. In this case it

is possible to interpret the commissioner's

decision as a disallowance of all the

ClT30/l/ND 54 6/9/89
Dalco(2)

objections, so that the taxpayer has a

right of appeal in relation to all of

them - limited as already stated by other

provisions of the Act. But the commissioner's

decision included a statement that it had

been decided to "admit your claims to the

extent indicated on" certain notices of

amended assessment. Those notices do not

show in any definite manner to what extent

each objection has been allowed or disallowed.

Such a practice is confusing, as it tends
to defeat the object of the Act in failing
to present a clear issue to the court in the

event of an appeal.

And, Your Honours, at page 101, about half-way

down the page, in the lengthy paragraph, the fifth

line, Mr Justice Starke said:

(Continued on page 56)

C1T30/2/ND 55 6/9/89
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MR JACKSON (continuing):

It is the commissioner's duty to consider a taxpayer's objections, and either to allow

or to disallow them, wholly or in part. But

to inform the taxpayer that he can discover

from an amended assessment the extent to which

his objections are allowed is no performance

of that duty, and still less is it so, where,

as in this case, it is quite impossible to
ascertain what items the commissioner has
allowed or disallowed. Much of the time of this

court might have been saved if the commissioner

had observed the plain directions of the

INCOME TAX ACTS.

Your Honours, both those references indicate what,

in our submission, is correct and that is that the

purpose of these provisions is so that in

the ehd clear issues arising on the objections

will be before the court on the hearing of the appeal.

TOOHEY J:  I am not sure that I follow that,Mr Jackson. The

obligation ~st up-on the Commissioner by

section 186 is to disallow an objection or to allow

it either wholly or in part. There is noth:ing in the section,
for whatever might be thought of the merit of doing it,

which requires the Commissioner to provide reasons

for the dis allowance of the objection, is there?

MR JACKSON:  No, I am sorry, I was not suggesting that,
Your Honour. What I was· . submitting was this , that

Your Honour will see that section 186 says that

the Commissioner has to serve the taxpayer with a

written notice of his decision, and that is the

decision on the objections and,in our submission,

as TRAUTWEIN's case indicates, that provision means

that what the Commissioner has to do is to indicate

what objections have been allowed or disallowed so

that it is possible to see, at that point, whether

an objection has or has not been successful, with a view to limiting the matters which might be the subject of an appeal or might be agitated by the
appeal.
TOOHEY J:  I understand that. I thought you spoke of the

processes in some way designed to ensure that

issues were clearly presented to the Court, but

that must be regarded as limited to the particular

objections and those which have been expressly
disallowed. In other words, there is nothing in

those sections which would point up for the Court

disallowed. the basis upon which an objection had been
CIT31/l/CM 56 6/9/89
Dalco(2)
MR JACKSON:  No, but Your Honour, what I am seeking to make
about it is this:  the taxpayer is obliged to state
fully and in detail the objections.  Now, that

means that the taxpayer must do just that, of course.

What the Connnissioner has to do, by section 186, is to consider each objection and then give notice

of those which he has allowed or disallowed and

whether he has done so in whole or in part. That

means that, in respect of some of the objections

if they are allowed, that issue is no longer live,

in respect of an objection which has been allowed
in part, the issue is pro tanto no longer live,
and in respect of an objection which is disallowed

it remains live the matter which can be the

subject of an appeal.

Your Honours, the taxpayer is given a right to

appeal or to a review by section 18 7 . .And if Your Honours

go to section 187, what Your Honours will see is that

it provides that a taxpayer who is dissatisfied

with a decision under section 186, on an ob.i ection

may lodge either a request to refer the decision

to the tribunal or a request to refer the decision

to a specified supreme court. Now,Your Honours,

the decision there referred to is the decision

referred to. in the opening words of the section and

that is a decision, under section 186, on an

objection.
Your Honours, the appeal which takes place

in consequence of that or the review, is an appeal
or review in relation to that decision, and that is

what the s.e.ctibn says. When I say ~hat is what the

section says, that is provided for, Your Honours, by

section 189 as well as by section 187.

(Continued on page 58)

CIT31/2/CM 57 6/9/89
Dcilco(2)
MR JACKSON (continuing):  Your Honours will see in relation

to section 189(2) in relation to a decision which

is to be referred to the tribunal that:

The referral of a decision on an

objection ..... be deemed to constitute

the making by the taxpayer of an

application to the Tribunal for review

of the decision.

The decision in question being the decision on

an objection which must take one back to

section 186 and, in particular, Your Honours, in

relation to the Court, Your Honours will see

under subsection (3) that:

The referral of a decision on an

objection to a Supreme Court constitutes
the instituting by the taxpayer concerned

of an appeal against the decision, and

that appeal shall be heard -

and so on. Now, Your Honours, the appeal that is

being contemplated there is the appeal against the

decision of the Commissioner not to allow the

objection or not to allow it in full. Now,

Your Honours, in the case of an appeal, as

Your Honours will see from section 190(a), the

taxpayer is then limited to the grounds stated in

his objection when the Court is considering whether

the appeal against the disallowance of that

objection should succeed.

DAWSON J:  There is only ever one objection for an assessment

is there not, Mr Jackson, and that is an objection

that the assessment is excessive? There may be

various grounds for that objection and the grounds

may be allowed or disallowed and, therefore, the

objection allowed in whole or in part,,

but, there is only one objection ever and only one

objection in the sense that it is an objection that

the assessment is excessive. (Continued on page 59)
ClT32/l/JH 58 6/9/89
Dalco(2)°
MR JACKSON:  Your Honour, with respect, my submission 1s

that it is not right.

DAWSON J:  That is the way the Act speaks of it: a single

obiection and multiole grounds.

MR JACKSON:  Your Honour, no doubt that is right - I am sorrv,

Your Honour, I am putting it badly - that is correct

in the sense that one lodges an obiection against the

assessment. The obiection has to state the grounds

and in that sense it is an obiection on a nu~ber

of grounds. When comes from that to section 186 - - -

DAWSON J:  The obiection is, is it not, that the assessment

is excessive?

MR JACKSON:  Well, Your Honour, it may be. Your Honour, that

is the result of it all, I think that is probably

right to say, although there are cases where the

contention might be on an objection, not that the

amount ultimately payable is too much in the

assessment, but that the assessment is done on a

wrong basis. Your Honour, I am putting that badly.

What I am seeking to convey really is that there

are cases - and Your Honours, the name of the

particular one escapes me just for the moment, but

it was, I think, one of the three doctor cases

that Your Honours heard some years ago, PINCUS and

the two other ones. Your Honours, what can happen,

of course, is that there is an assessment which is

done by the Commissioner on basis A which results in

there being a taxable income of X dollars. The

taxpayer's contention is that in the particular year
the taxable income was higher than that because

a different basis should have been adopted.

Your Honours, no doubt it would have some

consequence in respect of other years and that would

be the reason for advancing that contention.

(Continued on page 60)

ClT33/l/HS 59 6/0/89
Dalco(2)
MR JACKSON (continuing):  So that the objection really

would not b~ if one looks at it just in terms of

amoun 4 that the amount of the assessment is

excessive but that the basis of the assessment

was incorrect.

DAWSON J:  Well, in that case the objection would be that

the amount was excessive or too little but it

would still be the single objection and then there

would be grounds for saying that.

MR JACKSON:  Well, Your Honour, the - - -
DAWSON J:  And where it is excessive the onus is, of course,

on the taxpayer.

MR JACKSON:  Yes, Your Honour. Your Honour, what is

contemplated, we would submit, by section 189(3)

and the preceding provisions to which I have

referred, is that - and if one looks also at

section 190(a) - whilst it is right to say that

in the end perhaps there may be only one objection,

that is, that the assessment is excessive, that

the provisions deal distributively with the grounds

of the objection and, Your Honours, if one looks

for example, at section 190(a), what it is

contemplating is that an appeal be limited to
those grounds of the objection which have not been

decided successfully in favour of the - - -

DAWSON J:  Section 190(b) does not deal with them

distributively; it deals with them in globo.

MR JACKSON:  Yes, Your Honour, I am sorry, I was not

suggesting in relation to this argument that was

what it did. Section 190(a) limits the taxpayer:

to the grounds stated in his
objection.

Now, Your Honour, the grounds stated in the

objection, if successful at an earlier point,

would, oneWQll]_d expect, have had the result that

there has been some alteration in the assessment

and the assessment remaining to be dealt with is

one which is altered in some way in the sense that

(Continued on page 61)

ClT34/l/JH 60 6/9/89
Dalco(2)
DAWSON J:  What I had in mind - I do not want to keep you

any longer - is that you may establish a ground,

or more than one ground, but it may not establish

that the assessment is excessive. Therefore, if

one does not establish that, one does not

establish one's objection.

MR JACKSON:  Your Honour, that may be so in some cases

in the sense that one could well understand,

particularly since the advent of the word

processor, that objections can become terms of

art in a sense and have many grounds listed

and the fact that one ground might not be

sustained does not mean the same sum of money

would not form part of assessable income, or

not be an allowable deduction for some other

reason in the sense that it does not always
follow that for a ground to succeed it means that

the amount will vary, but it frequently would. Your Honours, I referred earlier to the

fact that the service of a notice of assessment

imposes limitationsupon both the taxpayer and

the Commissioner and I have so far referred to

the limitations upon the taxpayer. Your Honours,

the Commissioner, of course, is limited in his

powers to amend assessments once the notice of

assessment has been served and he may not do

just as he pleases. Your Honours, in that

regard I would refer Your Honours to section 170
and to the limitations upon the Commissioner's

powers contained in it, and, Your Honours, to

the observations made by members of the Court

in that regard in BATAGOL V THE CO:t1MISSIONER

OF TAXATION, (1963) 109 CLR 243 and in particular

at page 253.

(Continued on page 62)

CIT35/1/JM 61 6/9/89
Dalco(2)

BRENNAN J: Where is this leading us, Mr Jackson?

MR JACKSON: 

Your Honour, what I am seeking to submit is this: that the proceedings on appeal are proceedings in

relation to issues which, by that point, have become
defined. It may be that the definition results in
them still being broad but they are issues which are
defined and what I was seeking to do, Your Honour,
was to say that one of the things that occurs in this
regard is that once the process of assessment is
completed by the service of the notice of assessment
that fact brings about limitations, both on the
rights of the taxpayer and on the rights of the
Commissioner.

Your Honour, I have dealt with the limitation

on the rights of the taxpayer. I was going to deal

with the limitations on the rights of the Commissioner
and the purpose of doing that, Your Honour, is to

indicate, in the end, that with there being limitations,

as in section 170, it is unlikely, in our submission,

that the better interpretation of section 190 is

that the whole of the taxpayer's affairs, if I can
put it loosely, are then to be re-agitated in the

appeal.

BRENNAN J:  But is there not a fundamental difficulty in that?

MR JACKSON: Well, I hope not, Your Honour.

BRENNAN J:  I guess this comes back to what Justice Dawson

was putting to you, and that is that the starting point of it all is the taxpayer's objections. So all the points that emerge through this process

and fall for consideration on appeal are points

raised by the taxpayer. The question must always

be raised, "For what purpose?" and leaves unanswered

the question, "Is the purpose to determine whether

the assessment is excessive?"

MR JACKSON: Well, Your Honour, that assumes that one is

looking in the end for a purpose and then identifies

that as the purpose. What really one is doing - if

I could say this, Your Honour: one really does start a stage earlier, Your Honour. Taxation is not yet,

I think, voluntary - in one sense, anyway.

(Continued on page 63)

ClT36/l/DR 62 6/9/89
Dalco(2)
MR JACKSON (continuing):  To ma~e a person liable for

taxation there has to be an assessment relevantlv

and by that I mean that there has to be a

calculation, in one way or another, of the amount

for which he is liable and then completed by the

service of a notice of assessment. Now, Your Honour,

that really is the starting point and the notice

of assessment indicates the quantum of the liability.

Your Honour, that is the point at which the

Commissioner has committed himself, subject to

section 170, to his carrying out of the task

cast on him by the Act. Your Honour, in

relation to that the taxpayer is given the right to

obiect and he is given a right to obiect to that

assessment of what is his taxable income,

"taxable income" being, of course, the defined term.

Your Honour, when one says he is given the right to

choose the grounds of objection that is true, but

unless he succeeds in relation to his obiections -

and, Your Honour, I am conscious of using that word

in the plural - unless he succeeds in relation to

his grounds of objection, then the result is that

the assessment will stand, so that it is not

really surprising that he is the one who, in effect,

selects the ground, such as there is, for there being

an attack on the assessment. But having said that,

the assessment, of course, will stand, unless he

makes out one of the grounds on which he relies.

Now, he may make that after the satisfaction

of the Commissioner, in the first instance, or he

may not, but then make it after the satisfaction

of the court or the review. But, Your Honour, the

result of his contentions, or the acceptance of

his contentions will, no doubt, be, in almost every

case, that his liability for taxation is reduced.

But if one looks at the· words of the sections, in

our submission, they reflect that what the court
is doing is to examine whether the decision of

the Commissioner not to allow an ob_iection which,

in the context, we would submit, means not to allow

a ground of objection, was correct, the onus of

showing it was not lying on the taxpayer.

(Continued on page 64)

ClT37 /1/HS 63 6/9/89
Dalco(2)
MR JACKSON (continuing):  Your Honours, to say that the

whole purpose is to see whether the assessment was excessive is to take a provision, 190(b), which deals with how the burden of proof is to be allocated as between the parties in an appeal

is to take that provision and make it dominate

the nature of the appeal without looking first

at which the nature of the appeal is. I am sorry,

that is a long answer to Your Honour's question.

Your Honour was asking me where was I going with BATAGOL, I think I have just about got there

now, Your Honour. At page 253, at the bottom of

the page, Your Honours will see that Justice Kitto

says, having referred to section 170, in the last

six lines:

If this be correct, it follows that until

a notice of assessment has been served on

the taxpayer the Commissioner and his

officers neither need statutory authority

to go back over any or all of the steps that

have been taken in the office, and correct

anything they consider to be erroneous, nor

are disabled from doing so by anything in

s. 170.

Your Honours, what that suggests, in our submission

correctly, is that once the notice of assessment

has been served the Commissioner's powers are limited

and, Your Honour, to the same effect at page 256,

we would submit, about the middle of the page,
after references to section 170 and the whole of

the first paragraph.

But, Your Honours, the nature of the

proceedings, on appeal, can be seen also, in our
submission, in the judgments of the members of

the Court, in BAILEY V THE COMMISSIONER OF TAXATION,

(1977) 136 CLR 214.

MASON CJ:  Mr Jackson, it may be convenient to go to that
case after the adjournment.
MR JACKSON:  Yes, Your Honour.

AT 12.45 PM LUNCHEON ADJOURNMENT

C 1T38/1 /ND 64 6/9/89
Dalco(2)

UPON RESUMING AT 2.16 PM:

MASON CJ:  Yes, Mr Jackson?
"t1R JACKSON:  Thank you, Your Honour. Your Honours, I was

about to refer to the judgments of members of

the Court in BAILEY V FEDERAL COMMISSIONER OF

TAXATION, (1977) 136 CLR 214. Your Honours, the

leading judgment in that case is that of

Justice Aickin with whose reasons the other

members of the Court agreed. Your Honours, the

nature of the issue involved appears at page 225

commencing at about point 2 and the issue was

that there was a request for particulars of an~

arrangement under section 260 -

which was relied on by the Commissioner and some

matters which were ancillary to that. And the

contention on behalf of the Commissioner appears

at point 4 on the same page, that is:

that the Commissioner is not required to

indicate in advance what case he

proposes to make out -

on an appeal -

so that the taxpayer can know what

evidence he should adduce.

Your Honours, at page 226 point 2, going through to

page 227 about point 3, His Honour referred to the

argument that particulars could only be ordered as

they had been in a number of previous cases where
the matter at issue in relation to which the

particulars might be given was something concerning

an opinion of the Commissioner as distinct from

matters of fact not turning on opinion. Then,

Your Honours, commencing at page 227, His Honour

then went on to deal with the function to be

performed by particulars in an income tax appeal

and, Your Honours, the way in which His Honour dealt

with the matter and the terms which he used indicate,

in our submission, that the nature of the issues

involved on the appeal are those which we earlier

submitted were involved, namely, to decide the

matters not disposed cf by the decisions on the

objections.

ClT39/l/JH 65 6/9/89
Dalco(2)
MR JACKSON (continuing):  Your Honours, the language used by

His Honour, in our submission, is inconsistent with

the notion that the whole matter remains, as it were, at large. Could I go first, Your Honours, to point 3

on page 227, where His Honour said:

The purpose of particulars is to assist in

the defining of issues and there is in my opinion

no reason why in appropriate cases the Commissioner

should not give particulars where they are

necessary in order that both the appellant and the

court may understand the basis upon which the

assessment has been made.

His Honour goes on to say:

No doubt there are many cases in which the
return, the notice of assessment, the
alteration sheet and the notice of

objection will reveal the issues with

sufficient certainty so that no particulars

are necessary.

His Honour referred in the next six or eight lines to

the fact that it was a section 260 case, and then

said in the fourth last line in that paragraph:

If no more is said the taxpayer and the Court

are left entirely in the dark as to critical

matters and the issues remain undefined

except as to the ultimate conclusion contended

for by each party.

Now, Your Honours, in the last paragraph on the - Your Honours,

perhaps I should say this, it is true to say that the

context in which those observations are found is in

relation to a question of particulars, but they do

indicate, in our submission, the underlying legal basis.

And His Honour goes on to say, at the bottom of the

page:

There is nothing in the policy of the

Act nor in general considerations of policy to
require that the Commissioner should not inform
the appellant prior to the commencement of the
hearing of those details so that the case may
proceed in an orderly and comprehensible manner.

And, Your Honours, also at the bottom of the same

page:

The appellant should -

not -

have to speculate about, and adduce evidence to

negate, every possible kind of agreement or arrangement

and avoidance which the imagination of his advisers

can conjure up. Such a process is not merely time-wasting

but is likely to obscure the real issues.

C1T40/l/FK 66 6/9/89
Dalco(2)
MR JACKSON (continuing):  I would ask Your Honours to

refer to the whole of the remainder of that

paragraph at the top of page 228 and Your Honours

will see there that what His Honours is

contemplating is that there are defined matters -

I am not using defined in the sense of a

statutory definition but issues which are defined

to be dealt with on the hearing of the appeal and,

Your Honours, if one goes to page 229, at

about - perhaps I should sa~ if Your Honours

look at the whole of His Honour's remarks from

the first new paragraph on page 228 through to

page 229, the tone of them is to the same effect.

And then, Your Honours, at page 229

His Honour says, in the first new paragraph:

It is in my opinion wrong to regard the

power of the Court as confined to cases where
the assessment depends upon some statutory
discretion or opinion of the Commissioner.

Such cases are, in my opinion, no more than

illustrations -

In the next paragraph His Honour refers to

GEORGE's case but simply says:

there is nothing in the case which throws

any light on the question of particulars in

cases where the Commissioner states that the

assessment is based on s. 260.

And His Honour discussed other cases going through

then to page 230 and, in particular, about

page 230 point 7. Your Honours, at page 230, about

the middle of the page, referring to TOMLINSON's

case, His Honour said that he agreed with the

proposition which appears half-way through,

page 230 about point 6:

He did, however, conclude his review of the

authorities by stating that in the exercise of its discretion the court will give
paramountcy to the principle that the
appellant should have the fullest particulars
necessary to him to enable him to appraise
the case which he has to disapprove and
should have access to documents necessary
for the proof by him of this case.

(Continued on page 68)

C1T41/1/ND 67 6/9/89
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MR JACKSON (continuing): His Honour said he agreed with that.

His Honour then went on to say, at page 231,

Your Honours, at about point 3, that it was not:

a satisfactory resolution of the problem

of the need for particulars to say that it can

if necessary be dealt with when the appeals are

heard because that is to deprive the taxpayer of

an opportunity to prepare and conduct his case

so as to meet what is said against him. That

course has the practical defect -

which His Honour then refers to. Now, Your Honours, if one reads the whole of that paragraph and then to

the paragraph commencing at about page 231, point 7,

His Honour said:

there is no doubt that the court has power .....
under its inherent jurisdiction, to order the

Commissioner to provide such particulars of the

process of assessment as are necessary to

enable the real issues to be ascertained before

the case comes on for hearing.

His Honour then goes on to elaborate upon that in the

next paragraph and over to the top of page 232 and,

again, Your Honours, in the first new paragraph on

page 232. Now, Your Honours, what is apparent from

that, in our submission, is that His Honour is taking

the view that the question of the items which go to

make up the assessment - I am putting tha4 to which go to make up the assessment,~ the assessment,

of course, being the process in which the

Commissioner has been engaged - are items which are,

themselves, the subject of consideration, or the

correctness of them, is the subject of consideration
on the hearing of the appeal to the Court.

Your Honours, it is those matte~ in our submission, which are in issue.

(Continued on page 69)
ClT42/l/DR 68 6/9/89
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MR JACKSON (continuing):  Your Honours, could I indicate then

the other reasons for judgment in the same case,
the observations of the Chief Justice at page 217,

half-way down the page in the paragraph commencing

"Once these fundamental considerations are

observed", His Honour then goes on to deal with the

particular need arising in the case of particulars

in the case of section 260 cases, but goes on to

say in the last paragraph:

Quite clearly, the taxpayer is entitled to

know the basis on which the assessment has

been made. An ad~ustment sheet supplied

with the notice of assessment can be

expected to state and should state that

basis. The taxpayer should be told the

taxable facts.

At the top of the next page His Honour adverts to
the fact that the Commissioner may adopt alternative
bases, but he says he must be specific in his

identification in the end of the contract, and so

on. Then, Your Honours, His Honour said that

GEORGE's case, so far as it dealt with particulars

at least, bore no resemblance or analogy to the

situation in the present case. Your Honours,

Justice Gibbs, at the same page, page 218 at the bottom of the page,referred to the suggestion that:

the administration of the revenue laws

might be hampered if the Commissioner

were required to give particulars,

because the Commissioner might commit

himself to some view -

which was not the correct one, and then His Honour

went on to say in the first new paragraph on page 219
of the need for particulars and, Your Honours, the
way in which those observations are expressed

suggest that one of the matters which will be in

issue on the hearing of the appeal, is the

correctness of the manner of assessment and I

should also say Your Honour, the present

Chief Justice, at page 220, in the middle of the

page said:

An order for oarticulars does no more

than require the Commissioner to furnish
in advance of the hearing particulars of the
case which he intends to present in court.
Such an order does not require the

Commissioner to disclose the evidence ..... it

is the function of particulars to indicate

the nature of the case to be presented

at the hearing.

Cl T43 /J. /HS fi/9/89
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MR JACKSON (continuing): And Your Honour went on to say:

There is therefore no foundation for the notion that the Commissioner stands

apart from ordinary litigants in some

special position in relation to the giving

of particulars ..... To conclude otherwise
would result not merely in injustice to the

taxpayer, who will remain in doubt as to the

Commissioner's case until it is presented

at the hearing, but also in unnecessary

preparations and in a hearing of unnecessary

length as the taxpayer endeavours to deal

with matters on which, as it may subsequently

transpire, the Commissioner is placing no

reliance whatsoever.

And Your Honours said - if I could go on to the

last paragraph of the reasons for judgment:

Indeed, there is very much to be said

for the view that fairness to the taxpayer

demands that the Commissioner should be

compelled to give particulars of his

assessment when it issues so that the
taxpayer is adequately informed as to the

manner in which the assessment has been

arrived at and may then determine whether

he will object to the assessment and

subsequently appeal.

What Your Honour then said, of course, is not

germane to the present problem, save that what

it does indicate, in our submission, is a

recognition, as is found in the reasons for
judgment of other members of the Court, that the

process adopted by the Commission in arriving at

his assessment is a matter which is to be agitated

on the hearing of the appeal.

McHUGH J: Does it go that far? Surely it means no more

than that if the Commissioner is going to make

a positive case then he can be required to give

particulars of it but even if he does make a positive

case , does th is case say anything as to where the

ultimate onus is?

MR JACKSON:  Your Honour, the ultimate onus is provided for

by section 19O(b), we accept. Nor does the case

say anything to contradict that, of course, as

one would not expect it to. But what does emerge from the case, Your Honour, is this, that it shows

two things: the first is that the hearing of an

appeal is not, as perhaps some of the roore widely expressed

views fran the earlier cases would suggest, is not something

in which the Carmissioner's assessment performs no greater

function than to give a number of dollars which have to be

knocked over one way or another.

ClT44/l/ND 70 6/9/89
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MR JACKSON (continuing):  The obverse of that of the second

point is that it does show that one of the matters

to be determined, in looking at whether the onus
under section 190(b) has been satisfied, is

whether the particulars, if I could put it that way,

that go to make up the assessment, or the items

that go to make up the assessment, are ones which

were properly included in whatever way they were

included. Now Your Honour, the - - -

McHUGH J: Well, supposing in a 167 case the Commissioner

says "Well there is my assessment. I am not going
to lead any evidence. You prove that it was
excessive". On your hypothesis the Commissioner

would still have to give particulars or might have to.

MR JACKSON:  Your Honour, he might have to, but can I put

it in this way, because - he might have to give

particulars of the basis of the assessment and,

Your Honour,that might be something which can be

relatively easily satisfied in the sense that

he might say, "Well, the basis upon which I had

made this assessment is that, first, I am unable to

say, with any certainty, what your taxable income

was during the particular year, therefore the

assessment has been based on, to put it shortly,

an assets betterment basis". That is one example.

Another example would be for the Commissioner to

be able to say that "I have formed the view that

a person occupying a similar position be yours or

engaged in a similar business would, in the ordinary

course of events, expect to have a taxable income

in a year of say $200,000 '\ So, Your Honour,

the particulars which he might have to give would be

particulars of that kind and would not, in that sense,

be onerous. In such a case the Commissioner would not

then have to do any more than to resist the appeal in

the sense that the taxpayer would call his evidence and

may or may not succeed.

But,Your Honour, if one has a situation where,as

here,the assessments which have been made by the

Commissioner are assessments which are based entirely on

saying a particular sum of money from a particular source

in a particular year is money which was yours and where

it is demonstrated that that is wrong, one is just left

then with a situation where all one has is the number

of dollars without the basis for it. That is really

the question that arises in the appeal.

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McHUGH J:  Well, I can understand that if the Commissioner

elects to fight the case on a particular basis

and a c.ourt might say, "Well, we will hold you

to your case", but that was not what happened here,

was it? The Commissioner called no evidence at all,

did he?

MR JACKSON:  Your Honour, I think that is right; yes, that

is right, Your Honour. However, as is apparent

from the earlier pages of the transcript of the
hearing, what happened was that the basis of the

assessment appeared in evidence at the start of the

case and the basis of the assessment was indicated -

they are exhibits E and F, Your Honour, and I will

give Your Honour that page in a moment where they

were but admitted - but they were admitted

without objection as showing the basis of the

assessment; page 78 it appears on, Your Honour.

BRENNAN J:  Mr Jackson, in a section 260 case, one is

faced ordinarily, I imagine, with a situation where

it_ _ is common ground that the assessment is

excessive if it is not for the setting aside of an

arrangement, contract or whatever and, therefore,

one needs to know what it is that has been set aside.

Is no:li that all that happens under a BAILEY case?

MR JACKSON:  Well, not really, Your Honour. With respect,

what has happened in a section 260 case is that

particular arrangements, if I can put it that way,

are said by the Commissioner to be void against him.

The result of them being void is that it changes

the way in which the distribution of moneys or

claims to moneys will otherwise fall. Now,

Your Honour, no doubt it is desirable that there be

particulars of how that happens; it does not always

result in there being m:,re mmey c11¢-GULLAND was the

particular case to which I wanted to refer earlier,

Your Honour; I will give Your Honours a reference

to that in a moment. But, Your Honour, there is no

more reason really why particulars would be given

in one case than in another -

BRENNAN J:  Well, except that one does not know whether the

Commissioner has set aside any transaction unless he tells you.

MR JACKSON:  Well, Your Honour, one might equally say that

one does not know how the Commissioner arrives at,

say, a sum of $92,345, unless he tells you.

BRENNAN J: 

We may not know how he arrives at it, but you would know what the application of the Act is to

the facts. But, you do not know what the
application of the Act is to the facts in a
section 260 case unless the Commissioner tells you.
ClT46/l/JH 72 6/9/89
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MR JACKSON:  Your Honour, of course, section 260 is said

to be self-executing and if it be self-executing

then one has as much deemed knowledge of

of one as of the other, with respect. But,

Your Honour, one is as much in the dark _ seeing

an assessment that contains a figure worked out

by the Commissioner in the Commissioner's judgment,

whatever be the basis for doing it and, Your Honour,

that really, in our submission, does not change the

nature of the appeal. I do not want to labour the point

but in a section 260 case what one would be saying

would be that there had not been such a contract,

arrangemen4 et cetera or things that follow on

from that. Your Honour, if it were apparent that

the basis upon which the assessment was a particular
figure was arrived at by the particular application

of section 260, then one would think that is the

realissue of the case and if that succeeds, it

succeeds.

(Continued on page 74)

ClT46/2/JH 73 6/9/89
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MR JACKSON (continuing): If there is something else that is not worked out in the case with a different result

then the Commissioner goes back to the Commissioner.

In relation to BAILEY's case, there was one further reference I was going to give and it is in the

judgment of Justice Jacobs at page 222, and for

practical purposes, the whole of His Honours reasons

for judgment on that page.

Your Honours, I was going to refer now to a number of submission made by my learned friend:

first was in relation to GEORGE V FEDERAL COMMISSIONER

OF TAXATION, (1952) 86 CLR 183. Now, Your Honours,

the particular passage in GEORGE's case is at page 201,

in the middle of the page. It is that, Your Honours,

the part which is prima facie, at least, against us,

appears to be that part which says, at the middle of

the page:

that the amount of taxable income for which he

has been assessed exceeds the actual taxable

income which he has derived during the year of

income -

and that the taxpayer must demonstrate that.

Your Honours, in our submission, the view that the

whole of the taxpayer's affairs in respect of any
year must be re-agitated - and I am conscious I

am putting that contentiously in saying that - is, in our submission, not correct. We would submit a

number of matters in relation to it. The first is

that the scheme of the objection and review and

appeal procedure, we would submit, leads to an appeal
being an appeal in relation to issues which are

unresolved by the decision on the objections.

Your Honours, in that regard, the second thing

we would say is that the view that one must see

whether there is any other source of income is, in

our submission, inconsistent with the notion that

the appeal is an appeal against a decision on the

objection.

against the decision disallowing the objection By that I mean, Your Honours, an appeal

in particular respects, or not allowing at all.

The third thing we would submit, Your Honours,

is that that decision is inconsistent with the

nature of an assessment in the sense that, if the

view there expressed is correct, it would apply in

all cases, whether they be section 166 or section 167
cases, and in cases involving at least section 166,

the position which would obtain, one would expect,

is that the assessment is, itself, not just a number

of dollars but it is the end result of a process,

the process, itself, being contemplated by the term

"assessment" as well as the result of the process.

ClT47/l/DR 74 6/9/89
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And, Your Honours, in our submission, the view in that part of GEORGE's case does not, we would submit,

take into account sufficiently the policy of

section 170, namely that the Cormnissioner himself

is subject to some limitations in relation to

re-assessment.

(Continued on page 76)

ClT47/2/DR 75 6/9/89
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MR JACKSON (continuing):  Your Honours, there is not a direct

conflict between them, but there is an element of

policy involved in section 170 which does not fit

too well, in our submission, with the concept

there provided, Now, Your Honours, we would submit

that it is appropriate for the court to reconsider
that case because there is some tension, if I could

use a sometimes fashionable word, between it and

BAILEY's case, where the approach, in our submission,

does appear to be different. The issue is obviously

one of importance and is one, Your Honours, which

should be settled for the future if it is not settled

already.

In our submissio~ it is not sufficiently

clearly settled by the decision in GEORGE's case,

as indeed the difference in opinion in the court

below indicates. Your Honours, could I then turn to

our learned friend's submissions in relation to TRAUTWEIN's

case, 56 CLR 63, and, Your Honours, if I could go first

to the judgment of Chief Justice Latham. Che thing

that does appear from His Honour's reasons for

judgment is that he does not, in fact, in our submission,

decide the issue in favour of the appellant in this

case. Your Honours, in that regard, could I turn

first to page 87, and Your Honours will se~ about

point 4, a reference to the judgment of Sir Isaac Isaacs

in MOREAU V FEDERAL COMMISSIONER OF TAXATION, and

His Honour, there, is simply citing what was said

by Mr Justice Isaacs.

Then, Your Honours, at page 88, His Honour -

perhaps I should say at page 92, at the bottom of the

page and going on to the top of page 93, he leaves

open the correctness of that case and the observations

which he makes at page 88, to which I will come now,

and also again at page 93, to which I will return

in a moment, in our submission, again leave the matter

open. Your Honours, could I go first to page 88, point 3,

where His Honour says:

I say "as a general rule" because,

conceivably, there might be a case where it

appeared that the assessment had been made

upon no intelligible basis even as an

approximation.

Now, Your Honours, that is the point this case was at

in the judgment of the majority in the Federal Court

because the basis upon which the assessments had been made were bases which they held not to be sustainable

at all, and His Honour goes on to say:

and the court would then set aside the

assessment and remit it to the commissioner

for further consideration -

which is what happened.

ClT48/l/FK 76 6/9/89
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His Honour goes on to say that:

It is not necessary ..... to consider whether

or not the statement which I have quoted from

MOREAU's case, interpreted in the manner

suggested, places too heavy a burden upon the

taxpayer in an appeal because, as I propose to

show, the taxpayer has not, in my opinion,

shown any error in the assessment. I add that

what I have said does not preclude the court from

deciding a principle upon an appeal

and remitting the assessment to the

cormnissioner for determination of the facts - What becomes apparent, Your Honours, is that in the

discussion of the particular facts, and Your Honours

will recall this was the assessment divided into,

I think, seven equal parts - His Honour decided against

the taxpayer because, whilst it was demonstrated

that the amounts were unlikely to be exact, of course,

in any particular year, what had not been shown by the

taxpayer - and this was where the burden of proof provision worked against him - what had not been

proved was that in any one of those years, the amount

was too much.

(Continued on page 78)

C1T48/2/FK 77 6/9/89
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MR JACKSON (continuing):  Your Honours, that that is so

appears at page 92, but also particularly at

page 93 commencing about point 3 in the third

line in the first new paragraph. After referring

to the provisions of section 36 and section 39,

His Honour says:

The facts stated in the case do not

establish that in any particular one

of the years in question the assessment is

excessive. The assessment for a particular

year may or may not be so execessive.

Upon the facts stated no one can say whether

it is so or not. The result of the statutory
prov1s1on -

that is the onus of proof prov1s1on -

is that, as the taxpayer has not

established, in respect of any year,

that the assessment is excessive, he is

liable ..... to pay tax upon the assessment

for each year.

Your Honours, the iudgment of Justices Dixon and

Evatt at page 111 supports, in our submission,

the view that one must look at the particular

assessment, meaning by that the assessment in its

fuller form, if I can put it that way. If

Your Honours look at page 111, about point 3, the middle of the page:

The burden lies upon him in the iudicial

proceedings which he is thus required to take of establishing that the assessment

or amendment imposes upon him a liability

to which the taxing provisions of the Act

do not subiect him. Within the limits of

his obiectlon he must show that the

assessment is contrary to law or to fact.

Your Honours, the placing by the obiection of

limits upon the case is, in our submission,

recognized, albeit in passing, there:

If so much is established, the court may

set aside the assessment and remit it for

reconsideration, or may itself determine

the amount of the liability. But error of

law or fact affecting the particular

assessment must appear.

Your Honours, Their Honours decided against the
taxpayer for reasons similar to those of the

Chief· Justice. That appears at the bottom of

page 11 to the top of the next page.

ClT49/l/HS 78 6/9/89
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Your Honours, if I could turn then to the

submissions made by our learned friends about
McANDREW's case and, Your Honours, I do not need to

go to the case itself. The contention urged by them

was that McANDREW's case turned really on the fact

that the right to apply section 170 was something

which would result in the assessment being

excessive if it had not been correctly applied, or

if there had not been a right to apply it.

But, Your Honours, that case was put on a broader

basis by the members of the Court who discussed it

in F.J. BLOEMEN PTY LTD V FEDERAL COMMISSIONER OF

TAXATION, 147 CLR 375, and Your Honours will

there see at page 375, in ·

the first and second paragraphs, the Court's view

about it - the start of the second paragraph:

This interpretation gives expression to

the policy which underlies, and is

manifest in, the statutory provisions.

Your Honours, I have referred already to the third

paragraph, to the reference "the framework of the

taxpayer's obiection'', and then, Your Honours, in

the next paragraph Your Honours refer to the fact t~at:

(Continued on page 80)

ClT49/2/HS 79 fi/9/89
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MR JACKSON (continuing):

the appellants argue that this view of

the operation of the Act does not offer

sufficient protection to the taxpayer in

the event of an abuse by the Commissioner

of his powers.

But the Court went on to say - Your Honour

the Chief Justice and Justice Wilson went on to
say, in effect, that on the hearing of the appeal

the taxpayer was entitled to dispute his

liability to tax.

Your Honours, a further matter with which I wish to deal is our learned friend's reliance

upon section 175. Your Honours, all that is said

by section 175 is that:

The validity of any assessment shall not be

affected by reason

of the fact -

that any of the provisions of this Act -

is not complied with.

Your Honours, we do not suggest that the

assessments made in the present case were invalid.
What is suggested is that the objections to the

assessments should have been allowed. Any

suggestion - if I could turn to another matter,

Your Honours. Any suggestion, we would submit,

that the method adopted by the Commissioner is

irrelevant - and this is coming back to a point

I mentioned before - is inconsistent with a number

of things which perhaps I could summarize briefly.

One is section 177(1) which makes the particulars

of the assessment as well as the amount of the

assessment something which is excepted from the

conclusive evidence provision on the hearing of
an appeal. The second feature, Your Honours, is

section 186 which requires the Commissioner to

consider and to disallow or allow an objection,

in whole or in part, and, Your Honours, the grounds

of objection to an assessment may be not just that

an assessment is too high but that it was done

on a wrong basis.

Your Honours, the third feature is section 185

and Your Honours will see in section 185 that

it refers in particular in subsection (2) to, in

the case of amended assessments, the fact that

a fresh liability may be imposed in 'respect of

any particular" - that is an expression used in

C 1T50/l /ND 80 6/9/89
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section 185(2) which indicates that the assessment

is something which consists of a number of parts.

And Your Honours, accordingly, we would submit

then that one looks at the - as I have submitted

earlier, one looks at the assessment as consisting

of a number of things or potentially consisting

of a number of things and one has to look at the

end to see what matters remain in issue. The Court,

on hearing an appeal, is not just dealing the matter

in globo.

Could I add one further thing, Your Honour.

In paragraph 8 of our learned friend's outline

of submissions, they submit that in this case

the taxpayer failed to displace the factual basis

on which the assessment depended. Your Honours,

in fact, that is not correct, with respect. That

was what they did dispace and the assessments were

left as being numbers of dollars.

Your Honours, I indicated before that

I would give Your Honours copies of the definition

section of the Act insofar as it was relevant.

May I do so now.

MASON CJ:  Thank you.

(Continued on page 82)

ClTSO/2/ND 81 6/9/89
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MR JACKSON:  Your Honours, one other reference I should

give the Court is THE FEDERAL COMMISSIONER OF

TAXATION V GULLAND, (1985) 160 CLR 55. The

passages dealing with Dr Gulland's position were

at page 64 and page 111, the assessment against

which he had appealed reduced his taxable income

from that which he had returned. Your Honours,

those are our submissions.

MASON CJ:  Thank you, Mr Jackson. Yes, Mr Handley?
MR HANDLEY:  Your Honours, in addition to Dr Gulland's case,

we should also draw the Court's attention to

HENDERSON's case, dealing with the assessment of

an accountant's partnership on either a cash

receipts basis or an earnings basis where, again, the

Commissioner's assessment was attacked on the ground

that it was too low. I do not really propose to

take Your Honours to the case beyond giving a

reference to it. The objection to the Commissioner's

assessment was entertained by Mr Justice Windeyer

and entertained again in the Full Court despite the fact that the taxpayer's complaint was not that the assessment for the year in question was too high in

amount. HENDERSON V FEDERAL COMMISSIONER OF

TAXATION, 119 CLR 612; there is some discussion of the matter by Mr Justice Windeyer at page 618

and then in the Full Court.

TOOHEY J:  Mr Handley, what, if anything, does

section 190(b), have to say in those circumstances?

MR HANDLEY:  Well, there is a discussion by Mr Justice Windeyer

as to where the onus lies in a situation where the

taxpayer comes before the court and says, "The

Commissioner has assessed me on a wrong basis. I
should be assessed on an earnings basis, not a

cash receipt basis, although in the year in question

it would actually increase my assessment". And,

Mr Justice Windeyer took the view that despite the

provisions of section 190(b), the onus remained on

the taxpayer of establishing his attack on the
assessment. We thought we ought to draw that

decision to the attention of the Court. It has to

be our submission, and it is our submission, that

in that situation the issue between the parties is

one which the statute does not allow to be

litigated at that stage just as, for example, the

question of how large a loss is, or whether

particular items in a particular year are assessable

or not, cannot be litigated if, in fact, there are

undisputed carried forward losses which exhaust the

amount of any disputed income or deduction. The

issue has got to be postponed until it turns out that
the taxpayer is complaining that the assessment is

larger than it ought to be according to the law and

ClT51/l/JH 82 6/9/89
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the true facts. That point was not taken before
this Court in HENDERSON' s case; the only point seems to be

that it was taken was some discussion about where

the onus of proof lay in the appeal and the

point seems to have been conceded or just allowed

to pass by. In our submission, a taxpayer cannot

legally complain under tne statute that his

assessment is too low.

(Continued on page 84)

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DEANE J:  I think it was adverted to in the leave application
in GULLAND was it not?
MR HANDLEY:  I was not there, Your Honour.
DEANE J:  I have some recollection of it being raised in a
Western Australian tax case - - -

MR HANDLEY: Well HENDERSON was a Western Australian case,

but Your Honour would not have been sitting

judiciously on that.

DEANE J: No, I do not think so, which means I think it was

raised in the leave application in GULLAND. I

do not know how it disappeared.

MR HANDLEY: 

Yes. Well, Your Honours, whether it was raised in the leave application or not, it does not appear

that the matter was squarely raised on the hearing

in GULLANDand it certainly was not squarely raised on the hearing in HENDERSON and, in my submission, bearing in mind what this Court said in McANDRtw

in particular and also in the other cases that have
already been referred to, excessive means "excessive
in amount" and a taxpayer who claims the assessment
is too low does not present a justiciable issue
to this Court, or to any court exercising federal
jurisdiction.

Your Honours, in my submissions this morning I did advert to the fact that an original appeal

against the federal tax assessment, which once came to this Court and now goes to the Federal Court and previously went to the State courts in exercise

of federal jurisdiction, is a matter in the original
jurisdiction of the court, and in my submission,
that fact does throw  some light on the approach
that the court takes to the assessment, in that
it is not a review of the decision-making process
of the administrative officer, the court decides
judicially how the rights of the parties should be
judged, and if I could merely give a reference
to a number of cases where this Court has discussed
the effect of an appeal to itself from both the
Tax Commissioner, the Registrar of Trademarks and
the Commissioner of Patents, and it has been said,
for example, in JAFFERJEE V SCARLETT ,"It is the
duty of the court to decide the matter as upon
an original application and not merely to decide
whether the decision of the Registrar can or cannot
be supported", and that consideration, in my
submission, underpins the actual provisions of the
INCOME TAX ACT to which we have referred.
CIT52/l/CM 84 6/9/89
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I just merely give these references:

JAFFERJEE V SCARLETT, .a.trade imrk.case,. 57 CLR 119

and 126; KAISER ALUMINUM & CHEMICAL CORPORATION

V REYNOLDS METAL CO., where Mr Justice Kitto

notices a number of tax cases and it is a


convenient source for those, 120 CLR 142; and

another trade mark case where Sir Owen Dixon

discusses this question of BAYER AKTIEN-GESELL-

SCHAFT V BAYER PHARMA PTY. LTD. 101 CLR 658,

and perhaps, Your Honour Mr Justice Brennan,

some of these issues were exhaustively considered

by the Federal Court in MANTLE TRADERS

and onus of proving facts and the like and the

Court may wish to look at that. It is not

inconsistant with any of our submissions, but does
consider at the Full Federal Court level a

number of these cases and the working of these

sections. MANTLE TRADERS is in 49 FLR 256.

(Continued on page 86)

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MR HANDLEY (continuing): Dealing with my friend's submissions

and going to what he has said since lunch-time,

Your Honour: he said more than once, "It was

demonstrated in this case that the assessments were

wrong" and he also said that the assessments were made on no intelligible basis and sought to apply

Chief Justice Latham's dictum in TRAUTWEIN to the assessments in this case.

Now, the majority in the Federal Court, in

my submission, did not say that these assessments

were made on no intelligible basis. They did refer

to TRAUTWEIN and did so only once:

at the bottom of page 199 and at the top of page 200.

At the last two lines at page 199, Their Honours

said:

likewise, if the making of the judgment in

question cannot be seen as having proceeded

upon an intelligible basis, even as an

approximation (cf. TRAUTWEIN).

That was not the ratio of a majority decision,

as can be seen from a few lines on page 226 where,

at line 23, they say:

it was open to the taxpayer to endeavour to

demonstrate that each of the assessments

(that is, each of the processes of assessment)

was excessive in that it was not warranted by

law. It is that submission which we have

accepted.

So, their "no intelligible basis" submission was not

accepted and was not applied by the majority. case, have not been shown to be erroneous.

(Continued on page 87)

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MR HANDLEY (continuing):  The process by which the

Commissioner reasoned to an administrative decision which later was evidenced in the assessments has

been shown to be affected by the application of
erroneous principles of law but that exercise,

having been completed, the assessment having been

issued, the basis of that assessment is,

'Mr Daleo, in the year ended 30 June 1977, you

received a taxable income of X thousand dollars."

That is the basis of the assessment.

The basis of the assessment is an opinion

formed by the Commissioner pursuant to

section 167 of the Act, namely, that the taxable

income - he has formed a iudgment as to the si?.e of the

appellant's - of Dalco's taxable income:

the Commissioner may make an assessment of

the amount upon which in his judgment income

tax ought to be levied, and that amount shall

be the taxable income of that person -

and that is the basis of the assessment and that

has not been shown to be wrong and is not shown
to be wrong merely because in the administrative

process leading to the Commissioner's administrative

decision the Federal Court has been able to discern

errors of law.

In our submission, Your Honours, BAILEY's

case is essentially concerned with the

Commissioner explaining to the taxpayer, in a non-167 case, just what his decision has been on

to disallow the objection and what his decision

has been on the assessment.

(Continued on page 88)

87 6/9/89

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MR HANDLEY (continuing):  This is thrown up by

Mr Justice Aickin's judgment at page 231 and I

would seek to just take a moment with this.

At 136 CLR page 231 at about point 6 on the page:

Whatever the position may be before the

appeal reaches a court of law there is

no doubt that the court has power, if
not directly under its rules, then
under its inherent jurisdiction, to

order the Commissioner to provide such

particulars of the process of

assessment as are necessary to enable

the real issues to be ascertained
before the case comes on for hearing.

And, His Honour goes on to explain what he had in mind by those statements and the process of

assessment does not concern, in our submission,

the Commissioner's reasoning or his decision-making

process but the nature of his decision.

There are many aspects of the Act in which
the inclusion of an item of income or

the disallowance of an objection by the

Commissioner in a manner which departs from

the return cannot be satisfactorily
litigated without particulars being given

by the Commissioner of the basis of his

assessment.

Now, that is not the basis of his assessment in the

sense of the reasoning process applied by the

Commissioner. The Court does not order particulars

of how the Commissioner reasoned to his conclusion;

what is being ordered is particulars of the

conclusion.

It is enough to give two illustrations

in relation to assessments under

section 166. If the Commissioner were

to disallow a deduction claimed by indicating

merely an increase in the amount of taxable income without indicating what the relevant deduction disallowed was, it would be

impossible for the appeal to proceed in
the court without the Commissioner provicing
such particulars.
ClT55/1/JH 88 6/9/89
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MR HANDLEY (continuing):  His Honour was obviously

contemplating a case where multiple deductions were claimed by the taxpayer. One only has to think of Westpac or BHP, for example, "deduction

disallowed, $1 million", would not indicate any

issue on which either the taxpayer or the Court

could come to grips and so the Corrmissioner would

have to be told -would be expected to tell in~

that taxpayer, "repairs disallowed as capital item",

or, "oil expenditure disallowed as outside division"

whatever, or so on, the Commissioner being

asked to give particulars of what his decision was, not his decision-making process, but what deduction

has he disallowed and in what amount so as to

throw up a justiciable issue with which the

taxpayer can come to grips:

Again if the Commissioner were to

increase the taxable income by an

addition to the amount of income

without identifying the nature of the

income included a challenge to such an

assessment in the court could not proceed

without particulars being given.

Mr Justice Aickin, of course, is talking about an

assessment under section 166 where the Commissioner

does not determine directly the quantum of the

taxable income. So the Commissioner would be

expected to indicate that he was including an

amount of interest or an amount of dividends,
proceeds on the sale of Blackacre, proceeds on the

sale of BHP shares, or something of that nature to

indicate what it was he was doing. But, of course,

BAILEY's case does not at all trespass on GEORGE's

case, in our submission, as Mr Justice Aickin was
very careful to indicate in this passage by
referring to an assessment under section 166 and,
indeed, it is clear, even from Sir Garfield Barwick's

judgment in BAILEY that the Court did not have before

determines the taxable quantum by an exercise of it a section 167 case where the Commissioner directly
judgment pursuant to section 167.

(Continued on page 90)

ClT56/l/HS 89 6/9/89
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MR HANDLEY (continuing): His Honour said that at page 218.

He said:

The situation dealt with in that case

bears, in my opinion, no resemblance or

analogy to the situation to which the

Court must apply itself in this.

The "element", he said:

of the process of assessment in the particular

circumstances -

that is in GEORGE -

was not an application of the Act to a

factual situation: on the contrary, it

was an exercise of the Commissioner's power

to determine the principal fact to which the

Act should be applied.

Namely, the taxable income. So the basis of the

assessment in this case for purposes of an appeal

and objection is not to be found in the internal
documentation in the Commissioner's office, but it

is to be found in the statement that a default

assessment has been made and the taxable quantum

has been fixed at a nominated sum of money.

Your Honours, there was a discussion before

l\mch as to the circumstances in which section 167(c)

might operate which were not already covered by

section 167(a). It is perhaps not central by any

means to the case, but could I give Your Honours one

example where section 167 (c) might apply where section 167 (c)

would not? An entertainer might visit this country

for a month during April. It is known that he or

she is going to de9art before the end of the

financial year so that the statutory obligation

to lodge a tax return would not attach and normally

does not attach until some time around about

31 August, pursuant to a proclamation made by
the Commissioner under the Act. So in the absence

of a power in the Commissioner such as that

conferred by section 167(c), the visiting entertainer,

who may have done rather well by way of income from

Australian sources, would depart these shores with

the Commissioner having no power to raise an

assessment. He can then raise an assessment under

section 167(c) and, if necessary, take steps via

section 218, or otherwise, to collect the money.

(Continued on page 91)

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MR HANDLEY (continuing):  The taxpayer has not made default

but the Commissioner may have reason to believe

that that entertainer who has not furnished a

return has derived taxable income and a resident

who is proposing to depart before 30 June or, .indeed,

before 31 August would be in the same situation.

The Commissioner could raise an assessment for

purposes of enforcement, MAREVA injunctions and

the like. They are our submissions, if the Court
pleases.
MR JACKSON:  Your Honours, may I have leave to say one thing

and that is to- adopt a submission which my learned friend

attributed to me which I had not made earlier?

MASON CJ:  Yes.
MR JACKSON:  And that was, with respect, that I had said,

Your Honours, in our submissions, that the Court

should treat the case as one where there was no

intelligible basis shown. I had not :said that the

majority in the Federal Court had done so. But,

Your Honours, on closer examination of my learned

friend's contention that that was what I had said,

it is what the Full Court seems to have done and line 15, dealing with the 1977 tax year:

What does not appear is mateEial upon which a judgment might properly be based -

and so on. That seems, if Your Honours read further

down the page, to be applying also to the prior

year, 1976. Your Honours, if one goes from there

to page 219, about lines 1 to 8, the views adopted
in respect of the 1978 year appear to be the same

as those in respect of the prior year and, again,

Your Honours, at page 221, about lines 5 to 10.

BRENNAN J: Mr Jackson, those are the words on which yott

rely to found a submission that the Federal Court's

judgment falls within that exception to which

Sir John Latham referred?

(Continued on page 92)

C 1T58/1 /ND 91 6/9/89
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MR JACKSON: 

Yes, Your Honour, what I was really doing was: I am asking the Court - and this is the submission

we have made in the past, what we are submitting
is that the case is one falling within those
observations of Sir John Latham.  And, Your Honour,
what I am simply saying is that the court below
seems to have taken a similar view, although not
expressed in those exact words.

MASON CJ: And you are relying on the words "no proper basis"

in the two passages to which you have referred us

supporting that conclusion?

MR JACKSON:  Yes, and I was - - -
BRENNAN J:  You are not seeking to take us behind those words

to the facts?

MR JACKSON:  No, Your Honour. I was just saying that the
conclusion that the court arrived at. Now, Your Honour,
I was going to go to page 221, lines 1 to 10, then
in relation to the last year which was 1980, at
page 225, lines 26 to 32.

MASON CJ: That is all you wish to say about that?

MR JACKSON:  Yes, Your Honour.

MASON CJ: Yes, thank you, Mr Jackson.

MR HANDLEY:  Could I just say something, Your Honour, about

that? In my submission, what the court has said in

each of those passages, read in the light of their
ultimate statement, at page 226, line 26 is that they
have discerned errors of law in the decision-making
process of the Commissioner and so when they say

"no proper basis" et cetera, et cetera, they are

saying "no proper basis in law".

MASON CJ: An intelligible but improper basis.

MR HANDLEY:  Yes, but they are saying - and in my submission,
as, indeed - we have already this submission. It is
picked up to some extent in MANTLE TRADERS,

in Mr Justice Brennan's judgment in the Full Federal

Court. That gets the taxpayer nowhere unless he

discharges the onus of proving what are the relevant

facts.

MASON CJ: Yes, thank you, Mr Handley. The Court will consider

its judgment in this matter.

AT 3.21 PM THE MATTER WAS ADJOURNED SINE DIE
ClT59/l/DR 92 6/9/89
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Cases Cited

6

Statutory Material Cited

0

Trautwein v FCT [1936] HCA 77