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Commissioner of Taxation v Fortunatow [2020] FCAFC 139

Appeal from: Fortunatow v Commissioner of Taxation [2019] FCA 1247


TAXATION – personal services income provisions in the Income Tax Assessment Act 1997 (Cth) – personal services business tests – unrelated clients test – relationship between ss 87-20(1)(b) and 87-20(2) – proper construction of s 87-20(1)(b) – meaning of “as a direct result” – whether appeal competent – appeal allowed with costs

 

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