Sibai v CofT – Taxpayer loses appeal on scope of his ‘onus of proof’ – it was not limited to just the amendment amounts
On 3 Nov 2021, the Federal Court has upheld an AAT decision rejecting the taxpayer’s contention that he was required to prove only that discrete amounts of additional assessable income included in amended assessments were not assessable. The taxpayer sought judicial review of the AAT’s decision, contending that the AAT had no jurisdiction to consider any…