John George Russell v Commissioner of Inland  Revenue - SC 33/2012

Summary

Civil Appeal – Tax avoidance – Whether the applicant received a fair and impartial hearing – Whether the Court of Appeal was correct in its analysis of the evidence – Whether the Court of Appeal erred in finding that the overall arrangement established and operated by the applicant had the purpose or effect of tax avoidance – Whether the Court of Appeal erred in finding that the applicant was a person affected by the arrangement and that he obtained a tax advantage – Whether the Court of Appeal was correct to find that the assessment made by the Commissioner would not be void even if it included income deemed by virtue of s 99(4) of the Income Tax Act 1976 to be the income of someone else.CA  654/2010  [2012] NZCA128

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