Ian Cameron and Commissioner of Taxation
[2014] AATA 499
[2014] AATA 499
Division TAXATION APPEALS DIVISION File Number(s)
2013/4621-4622
Re
Ian Cameron
APPLICANT
And
Commissioner of Taxation
RESPONDENT
DECISION
Tribunal Mr P W Taylor SC, Senior Member Date 22 July 2014 Place Sydney The decisions under review are affirmed.
..................[sgd]......................................................
Mr P W Taylor SC, Senior Member
CATCHWORDS
TAXATION AND REVENUE – income tax – amended assessments disallowed PAYG credit claims – jurisdiction of Tribunal – penalty – whether to remit – decisions affirmed
LEGISLATION
Income Tax Assessment Act 1936 ss 6, 175A
Taxation Administration Act 1953 s 14ZZ; Sch 1 ss 12-35, 12-40, 15-10, 16-5, 16-20, 16-70, 16-75, 16-150, 16-153, 16-155, 16-170, 18-15, 284-75, 284-80, 284-90, 298-20
CASES
Cassaniti v Commissioner of Taxation [2010] FCA 641; (2010) 186 FCR 480
Constantinidis v Federal Commissioner of Taxation (2004) 55 ATR 348
Derry v Peek (1889) 14 App Cas 337
Federal Commissioner of Taxation v Ryan (1998) 82 FCR 345
Perdikaris v Deputy Commissioner of Taxation [2008] FCAFC 186; (2008) 172 FCR 412
Re Beiruti and Commissioner of Taxation [2013] AATA 634; (2013) 138 ALD 380
Re Taxpayer and Commissioner of Taxation [2014] AATA 106
Shawinigan Ltd v Vokins & Co Ltd [1961] 1 WLR 1206Vallance v R (1961) 108 CLR 56
SECONDARY MATERIALS
Taxation Ruling TR 2011/5 Income Tax: objections against income tax assessments
REASONS FOR DECISION
Mr P W Taylor SC, Senior Member
22 July 2014
Mr Cameron and his wife were the two directors and shareholders of Coast Continuity Services Pty Ltd (“CCS”) for the 10 years of its existence between incorporation, in October 2002, and winding up, in March 2012. Mr Cameron was the person who actually controlled, managed and conducted the company’s consultancy business.
In his 2011 and 2012 tax returns Mr Cameron claimed PAYG credits for amounts he said CCS had withheld.[1] In November 2012, prompted partly by CCS’s liquidation[2] and partly by the absence of evidence CCS had paid the allegedly withheld amounts to the Australian Taxation Office, the Deputy Commissioner of Taxation undertook an audit.
[1] Corporations are required to withhold part of the remuneration payable to employees and directors: see Taxation Administration Act 1953 (“TAA”) Schedule 1 ss 12-35, 12-40. The amount to be withheld is to be determined by reference either to schedules published by the Commissioner, or to the Income Tax Regulations 1936: see TAA Schedule 1 s 15-10. Amounts must be withheld when any payment is made, must be remitted to the Commissioner in a timely manner, and must be the subject of an annual summary provided to the recipient taxpayer: TAA Schedule 1 ss 16-5, 16-70, 16-75, 16-155, 16-170. Withholding the required amount discharges any liability to the taxpayer payee: TAA Schedule 1 s 16-20. But taxpayers are entitled to tax credits equal to the amounts withheld: TAA Schedule 1 s 18-15. (The credit entitlement depends on whether the employer withheld an amount from the employee, rather than on whether the employer actually paid the withheld amount to the Commissioner: Perdikaris v Deputy Commissioner of Taxation [2008] FCAFC 186; (2008) 172 FCR 412 at 422-3.) The Commissioner must apply the credit entitlement against the taxpayer’s tax debts, and refund any surplus, in accordance with TAA Part IIB.
[2] That liquidation was itself a response to a penalty notice the Commissioner had issued in March 2012 relating to CCS’s non-payment of its PAYG withholding liabilities for each of the five quarters from June 2010 to June 2011.
In January 2013, as a result of the audit, the Commissioner issued notices of amended assessment. These amended assessment notices disallowed Mr Cameron’s 2011 and 2012 PAYG credit claims. The Commissioner also considered that Mr Cameron had been reckless in failing to comply with his taxation obligations, and issued notices of assessment of shortfall penalty imposing 50% administrative penalties. The Commissioner adhered to his “amended assessment” and penalty decisions in the 9 July 2013 objection decision that is the subject of the present review application.
The contentious PAYG credit amounts, and the associated penalties, in each of the 2011 and 2012 tax years, are set out in the following Table. The Table includes the amount of CCS’s outstanding tax related liability to the ATO as at 1 July 2010 and the dates and amounts of all payments the company made to the ATO between 1 July 2010 and 30 December 2011.
2011 2012 2011 2012 Claim/Assessment Amended Assessment Taxable income 150,117 112,872 150,117 112,872 Assessed tax 43,493 29,713 43,493 29,713 Medicare levy 2,252 1,693 2,252 1,693 Flood levy 379 379 Franking offset 23 23 PAYG instalments CCS 54,915 36,192 0 0 BTP Australia Pty Ltd 0 1,105 0 1,105 Assessment Notice result -9,170 -5,536 45,745 30,656 Adjustment (prior Assessment) 0 0 9,170 5,536 Assessment Notice outcome -9,170 -5,536 54,915 36,192 Penalty Assessment (50%) 0 0 27,458 18,096 Total tax liability -9,170 -5,536 82,373 54,288 CCS payments to ATO 2011 2012 Opening Balance 83,294 95,673 28 July 2010 2,750 27 September 2010 3,019 30 March 2011 25,000 30 June 2011 38,000 12 July 2011 10,000 10 November 2011 15,400 Total payments 68,769 25,400
There are two notable aspects of the information set out in the preceding Table. The first is that the disallowance of Mr Cameron’s PAYG credit claim is the only significant difference between the original assessments (dated 14 March 2012 and 17 July 2012) and the 24 January 2013 “Notice[s] of amended assessment”. The second notable aspect of the Table is that CCS’s total payments to the ATO were less than its apparent tax related liability, including its accrued liability as at 1 July 2010.[3]
[3]I have extracted the payment dates and amounts from CCS’s bank statements for the period from 1 July 2010 to 30 December 2011. The statement information does not differentiate between GST, PAYG or GIC liabilities. The amounts differ from details contained in the ATO’s “running account balance”. The reasons for the discrepancy between the payment totals are not clear but, in the case of the 2012 tax year, would include the absence of bank statements for the last 6 months of the year.
The Commissioner’s position in the review proceedings was that PAYG credit disallowance does not form part of the “assessment” process, cannot be the subject of a valid objection against assessment for the purposes of s 175A of the Income Tax Assessment Act 1936 (“ITAA 1936”) and is not reviewable by the Tribunal in the exercise of the jurisdiction conferred by s 14ZZ of the Taxation Administration Act 1953 (“TAA”). The Commissioner contended that this position was dictated by the definition of “assessment” in ITAA 1936 s 6(1), and was supported by the decisions in Perdikaris v Deputy Commissioner of Taxation [2008] FCAFC 186; (2008) 172 FCR 412; Cassaniti v Commissioner of Taxation [2010] FCA 641; (2010) 186 FCR 480 at [174]; and Re Beiruti and Commissioner of Taxation [2013] AATA 634; (2013) 138 ALD 380. The Commissioner further contended that the Tribunal had to deal with any review of the penalty decisions on the factual basis that CCS did not withhold any PAYG amounts from its payments to Mr Cameron.
The submissions made on Mr Cameron’s behalf accepted that the Tribunal did not have jurisdiction to review the Commissioner’s PAYG credit claim disallowance. Mr Cameron’s contention was that if the Commissioner rejected his PAYG credit claim for the reason that CCS had not “withheld” PAYG amounts, then his assessable income was only the amounts he had actually received from CCS. In relation to the Commissioner’s penalty decisions Mr Cameron’s submissions involved the alternative propositions that (i) CCS had in fact withheld PAYG amounts, or (ii) he was neither reckless nor careless in claiming that CCS had withheld PAYG amounts.
The Commissioner’s issue of notices of “amended assessment” results in some apparent incongruity when it is viewed against the background of the Commissioner’s principal contention that his decision to disallow Mr Cameron’s PAYG credit claim does not constitute a reviewable “assessment” decision.[4] There is even less attraction in the Commissioner’s related submission that the Tribunal should exercise its review function in relation to the penalty assessments without regard to the actually “correct or preferable” finding about the contentious “withholding” asserted by Mr Cameron.
[4] Taxation Ruling TR 2011/5 Income tax: objections against income tax assessments states (at paragraph [111]) that an assessment notice may contain information beyond that contemplated by the definition of “assessment” and gives PAYG instalment credits as an example.
Mr Cameron’s response to the Commissioner’s contention is that his assessable income is limited to the amounts CCS actually paid him. That response, together with the apparent incongruity in the Commissioner’s principal contention, incline me to approach the matter by addressing the factual position underlying Mr Cameron’s claimed PAYG credit entitlement, before determining the Commissioner’s jurisdiction contention. These reasons follow that course.
CCS DID NOT “WITHHOLD” ANY AMOUNTS
Mr Cameron’s management and administration of CCS was characterised by lamentable informality, at least in the 2011 and 2012 tax years. The company did not have anything like a conventional accounting system. CCS did not use either accounting software or physical “books of account” (that is, cash books, journals and ledgers). Such financial management as did exist appears to have involved Mr Cameron merely using the company bank statements and preparing, although probably not in any regular and timely fashion, spreadsheets collating and analysing apparently relevant information.
In relation to Mr Cameron’s employment by CCS there was nothing in the nature of either a formal written agreement, or even an informal record, that determined his responsibilities, entitlements or level of remuneration. CCS never issued him with any pay slips. The only identified records which even purport to evidence the PAYG amounts on which Mr Cameron relies were (i) quarterly BAS statements which, in the 2011 and 2012 tax years, he typically prepared many months after CCS’s payments to him and long after the BAS statements were due, (ii) backdated company minutes that were prepared in an attempt to satisfy the Commissioner’s 8 November 2012 audit enquiries, and (iii) a payment summary, apparently dated January 2013, for the 2011 year.
The readily apparent imprecision of CCS’s financial management, and the absence of genuinely contemporaneous relevant payment records, reflect the reality of the way that Mr Cameron controlled and managed the company’s affairs. He understood that CCS and he had separate legal status, appreciated the potential benefit in the company’s limited liability status, and did broadly differentiate between “company” and “personal” expenditure. But beyond that broad differentiation, Mr Cameron, and through him CCS, never really identified and understood the nature and extent of their respective obligations and entitlements. He appreciated, at least in a general sense, the need for the company to be able to meet all of its financial obligations, including its taxation liabilities. He intended, and either believed or at least hoped, that it ultimately would. But that general appreciation and intention was not matched by contemporaneous practices and procedures that evidenced proper management and control of the company’s financial affairs. Despite recognising a difference between “company” and “personal” expenditure, he treated the company’s bank account as available to meet his own personal expenditure. He drew on the company’s available funds, as and when he chose, without any real regard to his own objectively demonstrable entitlements and without specific consideration of CCS’s responsibilities in relation to the “personal” payments it made.
Mr Cameron caused CCS to make three kinds of payments for his personal benefit. The first kind was approximately fortnightly payments from the company’s bank account to an account he held jointly with his wife. (The fortnightly payment amount during the 2011 tax year was typically $2,000. During the first six months of the 2012 tax year the payments were less regular and varied between $2,000 and $2,500.) The second kind of CCS’s payments was monthly deposits (of about $1,700) to Mr and Mrs Cameron’s joint home loan account. The third kind of payments was personal expenses which Mr Cameron paid direct from CCS’s bank account – either by cheque, internet transfer, or ATM/EFTPOS transactions.
Until about September 2011 Mr Cameron does not appear to have made any attempt to quantify the payments he had received in the 2011 tax year. It was in mid September 2011, some nine months after its original due date, that Mr Cameron prepared and lodged CCS’s Business Activity Statement for the period from July to September 2010. In order to prepare this Business Activity Statement Mr Cameron reviewed CCS’s bank statements. He differentiated between bank fees, business expenses and personal withdrawals (including the transfers to the personal and loan accounts to which I have referred above). He tallied these expenses and hand annotated each monthly bank statement with the relevant totals. Mr Cameron also examined the company’s cheque book and identified from the cheque butt details any additional personal expenses. Mr Cameron then prepared an Excel spreadsheet which typically had the following components:
Item Description 1 The monthly total of “personal withdrawals” from CCS’s account 2 Particulars of additional cheques CCS had drawn to meet personal expenses 3 An adjustment for any CCS expenses paid from “personal” funds 4 A subtotal described as “Overall Net wages” 5 A calculated “Gross” amount (calculated on an assumed 40% tax rate) 6 A calculated “Tax owing” amount (that is, “Gross” – “Overall Net wages”) 7 A revised “Gross” (reflecting a deduction for Mrs Cameron’s “wages”) 8 A tax amount based on the revised “Gross” (again assuming a 40% tax rate) 9 A further amount – “Revised tax less $2,500”
The spreadsheet components provided the information Mr Cameron subsequently included in the PAYG section of the various Business Activity Statements he submitted after September 2011. The “revised gross” amount (Item 7 in the Table) was used as the “Total salary” in the BAS, and the “revised tax less $2,500) (Item 9 in the Table) was used as the “Amount withheld from payments”.
All of CCS’s payments to or for Mr Cameron during the 2011 and 2012 tax years were made in the manner I have described above. All of the spreadsheet analyses were performed after the payments had been made and, in most cases, long after they had been made. No attempt was made, either at the time of payment or subsequently, to determine the actual amount of Mr Cameron’s payment entitlement or the actual amount of the PAYG instalment that TAA Schedule 1 s 15-10 required to be withheld. Neither did CCS undertake any contemporaneous accounting or administrative practice that recognised (in the sense of either recording or making specific provision for) any tax liability in relation to the payments it had made.
The absence of any contemporaneous records of the kinds to which I have referred in the previous paragraph provide a basis for inferring that CCS did not “withhold” any amount from the payments it made to Mr Cameron, or for his benefit: see Cassaniti v Commissioner of Taxation [2010] FCA 641; (2010) 186 FCR 480 at [170]-[172]. That inference is strengthened by CCS’s apparent non-compliance with other obligations. An employer who withholds payment of an employee’s remuneration entitlements has certain reporting obligations. They must give timely notice to the Commissioner in the approved form – typically in a Business Activity Statement: see TAA Schedule 1 ss 16-70(1); 16-75(4) and 16-150. The employer must also give a timely annual summary report, again in the approved form: see TAA Schedule 1 s 16-153(2). CCS did not provide timely notices, did not provide a timely 2011 annual summary and did not establish that it had provided any summary for the 2012 tax year.
CCS’s available bank statements show that for most of the 2011 and 2012 tax years, after the payments it made to Mr Cameron there was still a credit balance that was, typically, greater than the amount of the PAYG credits Mr Cameron claims as amounts that CCS had withheld. But this observation is of little significance. The mere fact that CCS had an obligation to withhold is not sufficient to establish the fact of a contemporaneous withholding: see Cassaniti v Commissioner of Taxation [2010] FCA 641; (2010) 186 FCR 480 at [173]. Neither can the appearance of periodic credit balances in its bank statement be regarded as probative of any relevant “withholding”. Such an inference could only be made, if at all, in the light of an accurate understanding of the company’s affairs (including its accrued liabilities, and the allocation of funds to meet them) at the time the payments were made. The informality of CCS’s payment practices, and the absence of any relevant accounting procedures, permit no more than the observation that CCS made payments to Mr Cameron, or for his benefit. There is no factual basis to justify a finding that CCS actually “withheld” any amount from Mr Cameron.
JURISDICTION TO REVIEW PAYG CREDIT DISALLOWANCE
For the reasons I have set out above, Mr Cameron has failed to establish that CCS “withheld” payments from him. That failure results in the comparative immateriality, for the resolution of the present application, of the Commissioner’s contention that the Tribunal has no jurisdiction to review the disallowance of Mr Cameron’s PAYG credit claims.
As I indicated earlier (in paragraph 6 above) the Commissioner’s contention is supported by previous decisions. In Perdikaris v Deputy Commissioner of Taxation [2008] FCAFC 186; (2008) 172 FCR 412 the Full Court of the Federal Court of Australia dealt with an application under the Administrative Decisions (Judicial Review) Act 1977 where a taxpayer sought to challenge the Commissioner’s refusal to grant credit for allegedly withheld amounts. The Full Court rejected a contention that the Commissioner’s refusal to recognise the taxpayer’s entitlement to a withholding payment credit involved a “decision under an enactment” – but dealt with, and rejected in any event, the taxpayer’s challenge (see 172 FCR 412 at 420). In Cassaniti v Commissioner of Taxation [2010] FCA 641; (2010) 186 FCR 480, where a taxpayer sought declarations about his entitlement to credit for allegedly withheld payments, although it was common ground between the parties that the credit issue did not form part of the assessment process, Edmonds J regarded that position as consistent with previous decisions – namely Constantinidis v Federal Commissioner of Taxation (2004) 55 ATR 348 and Federal Commissioner of Taxation v Ryan (1998) 82 FCR 345 at 363-4. In Re Beiruti and Commissioner of Taxation [2013] AATA 634; (2013) 138 ALD 380 Deputy President Forgie, applying the reasoning in Perdikaris, decided that the allowance of PAYG credits was essentially “an accounting exercise” and was not part of any assessment decision within the Tribunal’s review jurisdiction. That decision was subsequently applied in Re Taxpayer and Commissioner of Taxation [2014] AATA 106.
In the light of the findings I have made, it is not necessary for me to express any concluded view about the correctness of the Commissioner’s principal jurisdiction contention. That contention, despite the apparent incongruity it involves, is supported by the decisions referred to in the preceding paragraph. It is appropriate for me to follow and apply those decisions. However, the reasoning of those decisions does not compel the result that the Tribunal should exercise its penalty review jurisdiction without forming its own view about a contentious withholding by an employer. The thrust of the reasoning in Perdikaris, Cassaniti and Beiruti was that the allowance (or disallowance) of credit for amounts withheld was essentially an accounting exercise, the outcome of which depended upon the underlying facts and the characterisation of their legal effect. A determination that the “accounting exercise” lies outside the Tribunal’s review jurisdiction in no sense precludes the Tribunal from forming its own view about either that underlying characterisation, or the appropriateness of the “accounting exercise” the Commissioner has undertaken. This conclusion is consistent with the reasoning in Perdikaris where (at 172 FCR 419) the Full Court said:
[21] In our view the primary judge was correct when … he explained why the Commissioner’s conclusion as to the deductions did not affect the appellant’s legal rights or obligations. In proceedings in a court of competent jurisdiction to recover the amount of the assessments, the appellant would be at liberty to prove that his employer made the deductions or withheld the amounts. The Commissioner’s determinations are no barrier to that…
The same result follows, in my view, from the provisions of TAA Schedule 1 s 284-80(1). That provision, when applied to the relevant circumstances, determines when a taxpayer has a “shortfall amount”. So far as it is presently material, it requires a finding as to whether an amount that the Commissioner must pay or credit under a relevant taxation law “worked out on the basis of the [impugned] statement is more than it would be if the statement were not false or misleading”. This requires a factual enquiry about the true credit entitlement, in the manner contemplated by the Full Court in Perdikaris.
ASSESSABLE INCOME IS NOT LIMITED TO THE PAYMENTS RECEIVED
The absence of any specific evidence establishing Mr Cameron’s remuneration entitlement as an employee of CCS leaves open scope for the argument that his assessable income is limited to the amount of the payments he actually received. However the procedure that Mr Cameron adopted, in compiling CCS’s Business Activity Statements for the 2011 and 2012 tax years, involved calculating the approximate tax liability attributable to the payments he had received, and then using that information to record both his total remuneration and the amounts that CCS ought to have withheld from him. This practice is significant because it provides a basis for concluding that Mr Cameron and CCS conducted their affairs on the basis that the company would meet his income tax liabilities and that his total remuneration entitlement included both the direct payments that benefited him and an amount corresponding to the PAYG withholdings that CCS calculated as attributable to those payments.
The conclusion suggested by Mr Cameron’s practices in 2011 and 2012 is strengthened by his evidence that those practices were consistent with, and indeed a continuation of, what had occurred in the earlier years of the company’s activities between 2002 and 2010. I accept that this is so, and that the practices relating to the payment of his wages, and PAYG instalments, had remained the same throughout the period of the company’s operations. It follows that Mr Cameron’s assessable income was correctly set out in his income tax returns and, more specifically, the Commissioner’s assessment decisions.
PENALTY
A taxpayer who fails to exercise reasonable care is potentially liable to penalties for any material false or misleading statements made to the Commissioner in relation to the exercise of functions under a taxation law: see TAA Schedule 1 s 284-75. The kind of penalty that may apply depends on whether or not a taxpayer has a “shortfall amount” as a result of such a statement: TAA Schedule 1 s 284-90. A taxpayer will have a “shortfall amount” if, amongst other things, the impugned statement results in overstatement of the Commissioner’s apparent obligation to make a payment, or acknowledge a credit entitlement, under a taxation law: see TAA Schedule 1 s 284-80(1) Item 2. In such a case, the penalty will be either 75%, 50% or 25% of any “shortfall amount” – depending upon whether or not the taxpayer has acted with intentional disregard of a taxation law, has been reckless about the operation of a taxation law, or has merely failed to take reasonable care to comply with a taxation law: see TAA Schedule 1 s 284-90(1).
As I indicated in paragraph 3, the Commissioner’s penalty decisions proceeded on the basis of findings that Mr Cameron had been reckless about the operation of the applicable taxation laws. The concept of “recklessness” is used in various different types of legal analysis. In criminal law, for the purpose of characterising an accused person’s conduct as relevantly intentional, the concept includes conduct in which a person deliberately engaged with indifference to its likely consequences. Thus discharging a rifle at another person is “reckless” if the person is heedless of the risk of the projectile’s impact: see Vallance v R (1961) 108 CLR 56 at 61 per Dixon CJ. In the context of the tort of deceit, a representation has been characterised as “reckless” when the person had no actual belief in the truth of the statement and was indifferent to its inaccuracy: Derry v Peek (1889) 14 App Cas 337 at 350 per Lord Bramwell. In the context of a contractual clause excluding liability for negligence, except where a contractor “recklessly” supplied an unseaworthy vessel, the concept of “recklessness” was equated with a high degree of carelessness: see Shawinigan Ltd v Vokins & Co Ltd [1961] 1 WLR 1206 at 1214.
Mr Cameron’s conduct, as I have summarised it in paragraphs 10 to 13 and 16 above, merits characterisation as “reckless” for the purposes of TAA Schedule 1 s 284-90(1). Mr Cameron had no actual subjective belief that his practices complied with the income tax laws, and the lamentable informality of his practices and procedures is quite inconsistent with the exercise of reasonable care. He was grossly lacking in care in the management of his tax affairs and, more specifically, in the accuracy of information he submitted to the Commissioner.
DISCRETION TO REMIT PENALTIES
There is a general discretion to remit penalty amounts otherwise payable under the TAA: see Schedule 1 s 298-20(1). The proper scope for the exercise of that discretion must take into account the ordinary application of the TAA provisions and, in particular, the contemplation that base penalties will apply where a taxpayer with a shortfall amount has been “reckless” about the operation of a taxation law. The obvious purpose of the penalty provisions is to encourage compliance with taxation laws, and to impose significant sanctions where such a taxpayer had been grossly careless in their dealings with the Commissioner.
This legislative context is one where the discretion to remit penalties is generally expressed. There is no requirement that makes exercise of the discretion dependent upon a threshold satisfaction that the particular circumstances are special or exceptional. Nevertheless, the circumstances – which include any considerations that are apparently relevant to the exercise of such a generally expressed discretionary power – must provide a reason of substance to depart from the ordinary operation of the legislative provisions. Relevant reasons of substance may include (without being exhaustive) significant disproportion between the penalty amount and the base tax liability, the penalty amount, the taxpayer’s general good record and the hardship to which the penalty may give rise.
In the present matter CCS failed and went into liquidation. Prior to its liquidation, the progressive decline in Mr Cameron’s financial affairs is evident from the bank records, and from his accumulated tax liabilities (see paragraph 4 above). Those considerations suggests that the penalty amounts (which approximate $45,000) will be a significant financial burden for him. However that burden is a direct consequence of his own recklessness. And it is the kind of burden expressly contemplated by the TAA. I am not satisfied that it would be appropriate to exercise, to any extent, the discretion to remit the penalties that have been imposed.
DECISION
The decisions under review are affirmed.
I certify that the preceding 31 (thirty-one) paragraphs are a true copy of the reasons for the decision herein of Mr P W Taylor SC, Senior Member ...........[sgd].......................................................
Associate
Dated 22 July 2014
Date of hearing 24 April 2014 Date final submissions received 9 May 2014 Advocate for the Applicant Mr J Fox, The Fox Group Chartered Accountants Counsel for the Respondent Mr R Jedrzejczyk Solicitors for the Respondent Mr E Chiaw, ATO Review and Dispute Resolution
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