Pedley v Deputy Commissioner of Taxation [2019] FCAFC 130

TAXATION - appeal from decision of primary judge awarding judgment in favour of Commissioner - where director penalty notices issued - consideration of director's liability for withholding amounts - where basis for fact‑finding by primary judge challenged - consideration of s 269-20 of the Tax Administration Act 1953 (Cth) (TAA) - whether primary judge erred in not finding that certain payments made by the company were required to be applied by the Commissioner to the Company's liability to pay the withholding amounts the subject of the notice - consideration of the effect of a policy released by the Commissioner - whether Commissioner's allocation decision infected by jurisdictional error - consideration of s 8AAZLE of the TAA - appeal dismissed

Full decision here