Her Honour said, at para 71:
"The evidence shows that before the critical date Lilyvale and Enterprises Australia engaged in very different activities. It is true that Lilyvale’s income (on which it was liable to income tax) was sourced from the hotel, however it was the activity of Enterprises Australia that generated that income. Lilyvale’s involvement in the business of the hotel was so distant from the day to day activities of the hotel that, in my view, the course of conduct carried on in the hotel, bearing in mind the notions of continuity and repetition referred to in Federal Commissioner of Taxation v Murry...could not be said to be the conduct of Lilyvale."
Lilyvale Hotel Pty Limited v FCT  FCA 1031 (Federal Court, Stone J, 10 July 2008).
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