Softwood Pulp and Paper Ltd v FC of T 76 ATC 4439, illustrates the principle that losses
Question:
Softwood Pulp and Paper Ltd v FC of T 76 ATC 4439, illustrates the principle that losses and outgoings incurred before the commencement of income producing activity are not deductible under the general deduction provision. Similarly, Amalgamated Zinc (De Bavay's) Ltd v FC of T (1935) 54 CLR 29 is authority for the proposition that an outgoing incurred after the income producing activity has ceased is not deductible under the general deduction provision.
Advise if there are any specific tax provisions that may be found in ITAA 1997 or ITAA 1936, and any relevant principles arising from court cases subsequent to the 2 cases mentioned above, that may allow deductions for pre-commencement and post cessation of business expenses.
Income Tax Fundamentals 2013
ISBN: 9781285586618
31st Edition
Authors: Gerald E. Whittenburg, Martha Altus Buller, Steven L Gill