Source: Taxation In Australia Journal Article
Published Date: 1 Mar 2016
Part 1 of this article, published in the previous issue of this journal, considered the reasons that the taxpayer's credibility is critical to the successful resolution of audit issues and any subsequent Pt IVC proceedings in the Federal Court or Administrative Appeals Tribunal. This second and final part of the article considers the practical consequences for both a taxpayer and the Commissioner of Taxation in preparing for an audit and Pt IVC proceedings. A methodical approach to the analysis of contemporaneous records, prior statements concerning the material facts by the taxpayer (or the taxpayer's representatives) and third parties, for corroboration of the taxpayer's contentions or inconsistencies, will assist both th
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