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Fortunatow and Commissioner of Taxation (Taxation) [2018] AATA 4621

TAXATION – Income tax – Part 2-42 of Income Tax Assessment Act 1997 – Personal services income – Personal services business – Results test – Unrelated clients test – Work carried out through a recruitment company or some other intermediary – Offers or invitations to the public by LinkedIn advertising – Applicant not treated as having made offers or invitations by operation of s 87-20(2) of Income Tax Assessment Act 1997 – penalties – Finding of recklessness under s 284-90(1) of the Taxation Administration Act 1953 – Decision under review affirmed.
 

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