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The AAT has upheld the Commissioner's denial of deductions to participants for expenses they incurred as franchisees of Satcom Financial Services Pty Ltd. The AAT held that the claimed deductions were not allowable under either limb of s 51(1) ITAA 1936. However, the AAT held that no penalties should be imposed and remitted the matter to the Commissioner for amendment: Leggett and Ors and FCT [2007] AATA 1624 (AAT, Sweidan SM, 1 August 2007).

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