McPhee and Inspector-General in Bankruptcy
[2011] AATA 322
•13 May 2011
Administrative Appeals Tribunal
DECISION AND REASONS FOR DECISION [2011] AATA 322
ADMINISTRATIVE APPEALS TRIBUNAL )
) No 2009/5514
GENERAL ADMINISTRATIVE DIVISION ) Re MICHAEL MCPHEE Applicant
And
INSPECTOR-GENERAL IN BANKRUPTCY
Respondent
DECISION
Tribunal Mr A Sweidan, Senior Member Date13 May 2011
PlacePerth
Decision The Tribunal affirms the decision under review. (sgd) Mr A Sweidan........
Senior Member
CATCHWORDS
“Everett” Assignment – applicant assigned 50% of income from legal practice carried on in partnership with others – effect of such arrangement following dissolution of partnership and applicant’s subsequent bankruptcy – held assignment not operative in relation to income derived by applicant as a sole practitioner – such income derived solely by applicant
LEGISLATION
Bankruptcy Act 1966 ss 139J; 139L
TEXTS
GE Dal Pont and DRC Chalmers Equity and Trusts in Australia 4th edition Lawbook Co
HAJ Ford and WA Lee The Law of Trusts Lawbook Co
CASES
Atwell v Roberts [No 3] [2009] WASC 96
Casarotto v Australian Postal Commission (1989) 17 ALD 321
Commissioner of Taxation v Everett (1980) 143 CLR 440 at 454.3.
Commissioner of Taxation v Firstenberg (1976) 11 ALR 377
Commissioner of State Taxation v Cyril Henschke Pty Ltd (2010) 272 ALR 440
East v Repatriation Commission (1987) 16 FCR 517
Inspector-General in Bankruptcy v McGushin (2009) 178 FCR 27
McDonald v Director-General of Social Security (1984) 1 FCR 354
SJ Mackie Pty Ltd v Dalziell Medical Practice Pty Ltd [1989] 2 Qd R 87
Re Mann and Inspector-General in Bankruptcy (2001) 67 ALD 557
Re Mews and Federal Commissioner of Taxation (2008) 71 ATR 887
Rushton (Qld) Pty Ltd v Rushton (NSW) Pty Ltd [2003] 1 Qd R 320
REASONS FOR DECISION
13 May 2011 Mr A Sweidan, Senior Member Background
1. At the time of the decision under review the applicant was an undischarged bankrupt who became bankrupt on 30 April 2008. On 22 June 2009 the applicant’s trustee assessed the applicant with an income contribution liability of $32,277.40 for the contribution assessment period from 30 April 2008 to 29 April 2009. This contribution was calculated on a gross income of $175,000.81 from the applicant’s legal practice, which he conducted as a sole practitioner for the whole of that period.
2. The applicant contends that his income contribution for the relevant period should be calculated on a gross income of $87,500.00 and asserts that his wife Mrs Johanne McPhee in her capacity as trustee for the M.J. McPhee Family Trust (“Mrs McPhee”) is entitled to “hold and retain” 50% of the income from his legal practice pursuant to an “Everett” Deed of Assignment entered into on 26 June 1980 in respect of his interest in a partnership styled McPhee & Myer.
3. The issue is whether as asserted by the applicant this Deed of Assignment and subsequent events have the consequence that 50% of the income the applicant derived during the contribution assessment period from his legal practice as a sole practitioner was not income of the applicant. The respondent rejected that assertion and the applicant now seeks review of that decision by this Tribunal.
Evidence
4. In June 1980 the applicant was in legal practice with Mr Jonathon Myer. The applicant’s oral evidence was that there was no deed of partnership or other form of written agreement governing their partnership.
5. On 17 June 1980 a seminar was conducted in Melbourne following the decision of the High Court of Australia in Commissioner of Taxation v Everett (1980) 143 CLR 440. The Everett decision held that a partner’s interest in a partnership was a presently existing chose in action and recognising that a partner’s share in the profits of the partnership could be assigned. Assignments of partnership income as may subsequently be derived were popularly referred to as Everett assignments.
6. The applicant initially stated in cross-examination that he had personally attended the seminar in Melbourne and obtained the transcript. Shortly afterwards he retreated from that statement saying that he could not remember whether he had attended the seminar and may have obtained the transcript in some other way, he could not now recall.
7. The speakers at the seminar drew attention to the uncertainty of the position as to whether such assignments carry on past changes in the constitution of a partnership by the admission of a new partner or the retirement or death of a partner.
8. On 25 June 1980 the M. J. McPhee Family Trust was settled by Mr Myer with Mrs McPhee as trustee, and on 26 June 1980 the Deed of Assignment was executed between the applicant and Mrs McPhee whereby the applicant assigned to Mrs McPhee 50% of his interest in the partnership carried on under the style McPhee & Myer. The applicant’s partner Mr Jonathan Myer consented in writing to the assignment by endorsing the Deed of Assignment in accordance with the requirements of clause 4.
9. Subsequently, a capital gains tax was enacted with a 20 September 1985 date of effect: Income Tax Assessment Amendment (Capital Gains) Act 1986 s.19 inserting Part IIIA (s160L) into the Income Tax Assessment Act 1936. On 22 June 1989 the Commissioner of Taxation published Taxation Ruling No IT 2540 dealing with capital gains on disposal of partnership interests. In discussing Everett assignments, the ruling stated that for the purposes of Part IIIA the effect of an Everett assignment is that the partner disposes of part of his partnership interest and as it is unusual for such assignments to be made on an arms length basis the market value substitution rule in s 160ZD of Part IIIA would apply and the disposal will be at the market value of the partnership interest for capital gains tax purposes.
10. In March 1992 the Taxation Institute of Australia published the text of a settlement offer by the Australian Taxation Office for taxpayers who had entered into Everett assignments after 19 September 1985 and on or before 22 June 1989. The settlement terms required the termination of the assignment to be effected before 30 June 1992 and no further amounts of income to be assigned.
11. At unknown times between June 1980 and 1987 the McPhee & Myer partnership admitted new partners – Mr Barter, Mr Clarke and Ms Davis: see Deed of Assignment of Life Insurance Policies of the partners of the McPhee & Myer partnership.
12. At unknown times between 1987 and 16 August 1989 the McPhee & Myer partnership admitted new partners Messrs Martin and Pynt.
13. On 16 August 1989 the business name Michell Sillar McPhee Myer was registered and commenced 1 September 1989. The business name registration records the partners as Messrs McPhee, Myer, Barter and Clarke, Ms Davies and Messrs Martin and Pynt.
14. On 22 May 1990 Luxer Holdings Pty Ltd was incorporated and on 30 May 1990 Messrs McPhee, Myer, Barter and Clarke, Ms Davies and Messrs Martin and Pynt were each appointed directors of Luxer Holdings Pty Ltd.
15. On 4 December 1990 a Deed of Partnership was entered into for a partnership styled Michell Sillar McPhee Myer. Item 1 of Schedule 1 listed Messrs McPhee, Myer, Barter and Clarke, Ms Davies and Messrs Martin and Pynt as the partners and each executed the Deed. Clause 12(f) of the Deed of Partnership provides that no partner shall without the consent of the others assign his share in the assets or profits of the partnership or any part of such. Clause 14(a) of the Deed of Partnership provides that the death retirement expulsion or bankruptcy of any partner shall not dissolve the partnership between the remaining partners unless there shall be only one remaining partner.
16. On 16 August 1991 Ms Davies retired from the Michell Sillar McPhee Myer partnership.
17. On 1 July 1992 a Deed of Trust was executed creating the Luxer Unit Trust with Luxer Holdings Pty Ltd as trustee of the Luxer Unit Trust and entities associated with each remaining partner (Messrs McPhee, Myer, Barter, Clarke, Martin and Pynt) as the original unit holders.
18. Also on 1 July 1992 a service agreement was executed between Luxer Holdings Pty Ltd in its capacity as trustee of the Luxer Unit Trust described as the Manager and Messrs McPhee, Myer, Barter, Clarke, Martin and Pynt carrying on business as solicitors under the name Michell Sillar McPhee Myer described as the continuing partners and the Principal. Under the service agreement the Manager was appointed by the Principal to provide the Principal’s business with facilities and services as described in the service agreement. From this time Mrs McPhee was a unit holder of the Luxer Unit Trust and receiving distributions of income from that trust.
19. In cross-examination the applicant stated that he and Mrs McPhee did not execute a new Deed of Assignment or obtain the written consent of any other partner to the existing Deed of Assignment. He could not recall any discussion or taking advice in relation to capital gains tax and Everett assignments in the event of a partnership reconstitution. He claimed this was not of interest to him as his Everett assignment had been entered into before the date of effect for capital gains tax. Although volunteering more than once that all his partners had Everett assignments he claimed lack of knowledge as to whether any of his partners were affected by Taxation Ruling No IT 2540 and the Australian Taxation Office settlement offer or whether the partnership took advice on the matter at the time.
20. The applicant denied the suggestion that the service agreement with the Luxer Unit Trust was adopted by the partners as a means of income sharing with associates following the impact of the capital gains tax on Everett assignments. He was unable to recall any discussion or reasons for the delay between incorporating Luxer Holdings Pty Ltd in 1990 and the introduction of the service trust arrangement on 1 July 1992, but denied the suggestion that it was necessary to allow the partners to resolve their Everett assignments. He was also unable to recall any discussion he had with Mrs McPhee at the time about the Deed of Assignment and the introduction of the service agreement and the Luxer Unit Trust, but said that they had been married many years and had over the years discussed many things.
21. On 30 November 1992 Messrs Myer and Martin retired from the Michell Sillar McPhee Myer partnership.
22. At an unknown time between 4 December 1990 and 14 July 1993 the Michell Sillar McPhee Myer partnership admitted a new partner Mr Ryall.
23. On 14 July 1993 the business name registration of Michell Sillar McPhee Myer was cancelled and the business name Michell Sillar McPhee was registered commencing 1 July 1993 and recording the partners as Messrs McPhee, Barter, Clarke, Pynt and Ryall.
24. By 1996 the Michell Sillar McPhee partnership had reduced to two partners Messrs McPhee and Mr Barter. Mr Pynt having retired on or about 30 June 1994, Mr Clarke having retired on or about 31 March 1995 and Mr Ryall having retired on or about 29 March 1996.
25. On 10 July 1996 Mr Barter ceased work due to serious illness. On 20 April 1998 Mr Barter withdrew from the Michell Sillar McPhee partnership and the partnership dissolved pursuant to clause 14(a) of the Deed of Partnership. On 21 April 1998 Mr Barter’s registration as a person carrying on business under the name Michell Sillar McPhee ceased.
26. The affairs of the Michell Sillar McPhee partnership were settled on 20 April 1998:
26.1By a Deed of Assignment assigning the income protection insurance policy to Mr Barter;
26.2By a Deed of Covenant for the discharge of a liability to Glentham Pty Ltd;
26.3By the applicant, Mr Barter, their associates and Luxer Holdings Pty Ltd entering into a Deed of Settlement for the transfer of:
26.3.1the Barter shares in Luxer Holdings Pty Ltd to the applicant; and
26.3.2the units in the Luxer Unit Trust to Mrs McPhee.
27. On 10 June 1998 the shares in Luxer Holdings Pty Ltd held by associates of retired partners Messrs Pynt, Clarke and Martin were transferred to the applicant. The units in Luxer Unit Trust held by associates of Messrs Pynt, Clarke and Martin were transferred to Mrs McPhee. In his oral evidence the applicant described this as tidying up outstanding matters with former partners.
28. On 1 November 1999 the applicant registered for an ABN as an individual sole trader using the trading names – MJ McPhee Barrister & Solicitor and Michell Sillar McPhee.
29. On 18 August 2008 the applicant ceased registration as a person carrying on business under the name Michell Sillar McPhee and on 11 October 2009 Luxer Holdings Pty Ltd dissolved.
30. In cross-examination the applicant stated that on dissolution of the Michell Sillar McPhee partnership there was no valuation done of his partnership interest and that Mrs McPhee did not call for a valuation to be done. The applicant stated that no assets were to be sold and the management fee arrangement with the Luxer Unit Trust continued. From 21 April 1998 he conducted legal practice as a sole practitioner with Luxer Holdings Pty Ltd providing the administrative functions for the legal practice as it had done for the former partnership. Management fees paid to Luxer Holdings Pty Ltd for these services were distributed to Mrs McPhee as the unit holder in the Luxer Unit Trust until the time of bankruptcy when the applicant arranged a service agreement with another entity associated with his son.
The Tribunal’s Findings
The assessed income was derived by the applicant
31. Section 139J of the Bankruptcy Act 1966 requires a bankrupt who derives income during the bankruptcy to pay contributions towards the bankrupt estate. For the purposes of an income contribution assessment, “income” in relation to a bankrupt is defined in s 139K and s 139L of the Bankruptcy Act 1966 and has its ordinary meaning, subject to the qualifications in s 139L none of which are relevant here.
32. The ordinary meaning of income as used in s 139L connotes income of the bankrupt according to ordinary usages and concepts whether derived, received or earned from any source: Inspector-General in Bankruptcy v McGushin (2009) 178 FCR 27 at [12]-[19], [37]-[38] and Re Mann and Inspector-General in Bankruptcy (2001) 67 ALD 557 at [30]-[35]. Plainly the meaning of income is wide enough to embrace fees received by the applicant as a sole legal practitioner from providing his professional services by his own skills and exertion: cf Commissioner of Taxation v Firstenberg (1976) 11 ALR 377 at 392.5, 394.5, 396.7; Commissioner of Taxation v Everett (1980) 143 CLR 440 at 454.3.
33. The applicant claims 50% of his professional fees are not his income as a consequence of the Deed of Assignment. The applicant’s argument requires a careful examination of:
33.1the nature of the Deed of Assignment and the applicant’s obligations and the assignee’s rights under the Deed of Assignment; and
33.2the effect of subsequent events on the Deed of Assignment and the applicant’s obligations and the assignee’s rights under the Deed of Assignment.
34. In Everett the High Court held at 143 CLR 446.8, 448.5, 449, 450.5, 452.1 and 454.5 that a partner’s entitlement to participate in the profits of a partnership is not separate and severable from his interest as a partner in the partnership. The partner can assign his interest in a partnership which carries with it a right to a proportionate share of future income attributable to his interest in the partnership. The assignment binds the property assigned and is effective at once to confer on the assignee an equitable entitlement as against the assigning partner and the other partners to a share of the income subsequently derived by the partnership. This imposes on the assigning partner the duties of a trustee.
35. It is clear that an income share is payable to the partner as a partner and owner of a partnership share so long as the partnership remains on foot. Consequently the right of the assignee to the partner’s share of the income is vested in the assignee so long as the partner has an entitlement to participate in the profits of the partnership and the partnership remains on foot.
36. It is also clear that the extent of the assignee’s equitable interest is ascertainable only on the dissolution of the partnership and the assigning partner has duties to his assignee for the equitable interest ascertained on the dissolution of the partnership. To the extent that he may have given no account for that interest upon the dissolution he may be liable to account to the assignee and to an award against him for equitable compensation.
The assessed income was not assigned under the Deed of Assignment
A - No continuity of the subject matter of the Deed of Assignment
37. It is clear that what was assigned to Mrs McPhee by the Deed of Assignment was 50% of the applicant’s interest in a partnership styled McPhee & Myer with the written consent of the other partner of the partnership at that time, Mr Myer. There is no evidence that the Deed of Assignment survived the McPhee & Myer partnership between the applicant and Mr Myer. A partnership determines on the retirement of an existing partner or the entry of a new partner and the partnership the day after the reconstitution is a different partnership from that in business the previous day: see Commissioner of State Taxation v Cyril Henschke Pty Ltd (2010) 272 ALR 440 at 443[11]; SJ Mackie Pty Ltd v Dalziell Medical Practice Pty Ltd [1989] 2 Qd R 87 at 90-91, 87, 98; Rushton (Qld) Pty Ltd v Rushton (NSW) Pty Ltd [2003] 1 Qd R 320 at [9]; Atwell v Roberts [No 3] [2009] WASC 96 at [23]-[24], [31]-[33], [53]-[54].
38. By 1987 three new partners had joined the McPhee & Myer partnership. The applicant’s evidence was that at this point there was no partnership deed or written partnership agreement and by contrast with Mr Myer’s earlier written consent to the Deed of Assignment and the requirements of clause 4 of the Deed of Assignment there was no such consent by each subsequent joining partner.
39. The applicant stated that no such consent was given with the admission of further partners in 1989, notwithstanding the execution of the Deed of Partnership for the Michell Sillar McPhee Myer partnership on 4 December 1990 containing clause 12(f) forbidding assignment of a partnership share without the consent of the other partners.
40. Apart from the admissions of new partners there were a number of retirements of partners over the years and there is no evidence that the Deed of Assignment survived these dissolutions of partnership over the years. Consequently, the Tribunal finds that in the absence of evidence establishing the continuity of the Deed of Assignment, the subject matter of the assignment (i.e. the applicant’s equitable interest in the McPhee & Myer partnership) ceased to exist as early as the time of the admission of a new partner after 26 June 1980. Therefore, it is impossible in the opinion of the Tribunal for the Deed of Assignment to effect an assignment to Mrs McPhee of one half of the applicant’s gross income of $175,000.81 for the contribution assessment period from 30 April 2008 to 29 April 2009.
B - Abandonment of the Deed of Assignment
41. Further and alternatively the respondent submits and the Tribunal finds that if the Deed of Assignment had continued in force to effect an Everett assignment in relation to the applicant’s interest in the successive partnerships (which is denied by the respondent), by 1 July 1992 the Deed of Assignment had been abandoned for the service agreement with the Luxer Unit Trust.
42. It is clear that upon the Commissioner of Taxation publishing Taxation Ruling No. IT 2540 on 22 June 1989 stating therein the position he proposed to adopt in respect of the application of the capital gains tax provisions to Everett assignments, the use of such assignments to direct income to family members became unattractive due to the potential for capital gains tax liability. The concern this ruling raised caused the Commissioner of Taxation to offer settlement guidelines to taxpayers who had entered into Everett assignments after 19 September 1985 and on or before 22 June 1989. The settlement terms required the termination of the assignment to be effected before 30 June 1992.
43. The applicant did not accept that this was the position, claiming his assignment was a pre-capital gains tax disposition and also claims that he was not aware of what the other partners were doing about their Everett assignments or why the introduction of the Luxer Unit Trust and the service agreement took place on 1 July 1992.
44. The Tribunal finds that on the evidence a reasonable inference can be drawn that the Deed of Assignment and the Everett assignments of the applicant’s partners had become unattractive. In the Tribunal’s opinion it is clear that as a consequence the Deed of Assignment was abandoned by agreement between the applicant and Mrs McPhee and replaced by the service agreement between the Luxer Unit Trust and successive partnerships and finally with the applicant as a sole practitioner. Under this arrangement Mrs McPhee continued to receive income from partnership business but indirectly by way of a distribution of trust income from the Luxer Unit Trust. The applicant’s own evidence at Exhibit A1 paragraphs 49 to 66 is consistent with this position. This state of affairs existed from at least 1 July 1992 and, with Mrs McPhee’s consent, concurrence and acquiescence continued on for 16 years until the bankruptcy.
45. The Tribunal finds therefore that the Deed of Assignment does not effect an assignment to Mrs McPhee of one half of the applicant’s gross income of $175,000.81 for the contribution assessment period from 30 April 2008 to 29 April 2009. In the Tribunal’s opinion settlement of the claims of the applicant’s trustee in bankruptcy to a number of assets including office equipment (see Ex A1 paras 69-74 and annexures marked “71-A” and “71-D”) does not demonstrate that one half of the applicant’s income from his sole legal practice is Mrs McPhee’s income.
C – Final dissolution of partnership and satisfaction of rights under the Deed of Assignment
46. Further and alternatively the respondent submits that if the Deed of Assignment had continued in force to effect an Everett assignment in relation to the applicant’s interest in the successive partnerships (which is denied by the respondent), that assignment came to an end on the dissolution of the partnership styled Michell Sillar McPhee by the withdrawal of Mr Barter leaving Mr McPhee as the only remaining partner. In the Tribunal’s opinion that is quite clearly correct.
47. At this point the partnership styled Michell Sillar McPhee was dissolved and the subject matter of the assignment (i.e. the applicant’s equitable interest in that partnership) ceased to exist. What remained was the value of the applicant’s equitable interest in a partnership that was properly the subject of an assignment and the applicant’s responsibility to account for this equitable interest to his assignee. On the evidence the Tribunal finds that any responsibility the applicant had to account to Mrs McPhee was discharged through the settlement arrangements entered into on 20 April 1998. That is all the interests of the remaining partner and his associates in the Luxer Unit Trust were transferred to Mrs McPhee.
48. The applicant’s evidence was that his interest in the partnership styled Michell Sillar McPhee was not valued and no account of his partnership interest at that time was given or called for by Mrs McPhee. The reasonable inference to be drawn from the evidence is that consistent with the arrangement Mrs McPhee had accepted on or before 1 July 1992, she consented, concurred and acquiesced in accepting in satisfaction of any interest she had under the Deed of Assignment all the units in the Luxer Unit Trust. Such consent, concurrence and acquiescence by Mrs McPhee would be a defence to any action against the applicant for breach of trust: see HAJ Ford and WA Lee The Law of Trusts Lawbook Co at [18.3010], [18.3050], [18.3070], [18.3090] and GE Dal Pont and DRC Chalmers Equity and Trusts in Australia 4th edition Lawbook Co at [24.160]-[24.175], [30.140], [30.145].
49. Consequently the Tribunal finds that there is no basis in the Deed of Assignment for the applicant’s contention that one half of the applicant’s gross income of $175,000.81 derived from his legal practice for the contribution assessment period from 30 April 2008 to 29 April 2009 is not his income but the income of Mrs McPhee received by him in trust consequential on the Deed of Assignment.
D – Conflating derivation of income with any duty as trustee to give an account
50. The Tribunal also finds that the applicant’s argument incorrectly conflates the derivation of his income from his personal skills and efforts as a sole legal practitioner and the statutory requirement under Division 4B of the Bankruptcy Act 1966 to pay into the bankrupt estate a contribution from that income, with any duty he may still have as a trustee under the Deed of Assignment to account to his assignee for the value of his equitable interest in a partnership on its dissolution.
51. The duties are clearly different conceptually, in principle and in the obligations and processes that arise. In the present context there is no place for remedies in equity through the process of tracing and claiming traceable proceeds or substituted property, alternatively an account of profit made or compensation for loss: see KL Fletcher The Law of Partnership in Australia 9th edition Lawbook Co at [1.40], [2.100], [2.105], [5.40]; HAJ Ford and WA Lee The Law of Trusts Lawbook Co at [17.4030], [17.4300], [17.4550]; GE Dal Pont and DRC Chalmers Equity and Trusts in Australia 4th edition Lawbook Co at [3.145], [3.150], [24.75], [39.05], [39.10], [39.20] and Cf Re Mews and Federal Commissioner of Taxation (2008) 71 ATR 887 at 906[73]-[76].
Onus of proof
52. While, unlike in taxation matters, there is no onus of proof on the applicant in this matter, ultimately the Tribunal can only act on the evidence before it. If there was evidence supporting the applicant’s claim that the Deed of Assignment prevailed and that one half of his fee receipts is the income of Mrs McPhee, it is his responsibility to lay before the Tribunal all material necessary to his case: see McDonald v Director-General of Social Security (1984) 1 FCR 354 at 358.5; East v Repatriation Commission (1987) 16 FCR 517 at 534; Casarotto v Australian Postal Commission (1989) 17 ALD 321 at 334-335. There is no material put before the Tribunal that supports the applicant’s argument. The partnership minute books are silent on the assignment, but do indicate that tax advice was being obtained in connection with the Luxer Unit Trust arrangement.
Application to file further evidence
53. After the conclusion of the hearing the applicant applied for leave to file further evidence. This related to:
(i)a decision made by the respondent, allegedly for different reasons, in respect of a period subsequent to the contribution assessment period; and
(ii)what the applicant asserted was “unfair” use by the respondent in cross-examination of the applicant of documents not previously supplied.
54. The Tribunal declined to allow the applicant to file such evidence. In the Tribunal’s view these documents are not relevant to the issues in this application. Further the Tribunal notes that the applicant is an experienced legal practitioner who took no objection to the tender of documents referred to in (ii) above by the respondent during his cross-examination.
Decision
55. The Tribunal finds that the correct and preferable decision is for the Tribunal to affirm the decision under review.
I certify that the 55 preceding paragraphs are a true copy of the reasons for the decision herein of Mr A Sweidan, Senior Member
Signed:.............(sgd) Mr T. Chater......
Associate
Date/s of Hearing 16 November 2010, 9 February 2011
and 27 April 2011
Date of Decision 13 May 2011
Representative for the Applicant Self represented
Counsel for the Respondent Ms L B Price
Solicitor for the Respondent Mr D Estrin
Australian Government Solicitor
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