24 Jan 077 AAT applies Part IVA to grape growing scheme - MacphersonThe AAT has held that Part IVA applied to deny a taxpayer a deduction for expenses relating to a grape growing project, Central Highlands Wine Grape Project Ndeg. 3. The AAT held that, viewed objectively, the project was entered into by the taxpayer for the dominant purpose of enabling her to obtain a tax benefit in connection with the arrangement.
The AAT said, at para 49:
"But for Part IVA, the scheme operated so as to entitle Ms Macpherson to deductions totalling $46,000 in the 1997 income year upon the actual expenditure by her of $6,600. This clearly suggests that the dominant purpose of the project was to obtain a tax benefit."
Macpherson and FCT  AATA 1022 (AAT, Fice M, 22 January 2007).
For a copy of the decision, go here