Objections against income tax assessments : some practical aspects for tax practitioners

Objections and review against income tax assessments can be confusing for taxpayers and their advisers. One of the main reasons is that this area of the tax law requires an understanding of the Income Tax Assessment Act 1936 (Cth) (ITAA 36), the Income Tax Assessment Act 1997 (Cth) (ITAA 97) and the Taxation Administration Act 1953 (Cth) (TAA). In addition, the definition of an assessment has changed in recent times, as has the scope of objection rights and the clarification of the onus of proof in review and appeals. Such changes make it difficult for taxpayers and their advisers, who may not be dealing with these issues on a regular basis, to keep up to date.