The enigma of 'reasonably arguable positions': 21 years old but still teething

Woellner, Robin (2013) The enigma of 'reasonably arguable positions': 21 years old but still teething. In: Papers from the Australasian Law Teachers Assocation Annual Conference. From: ALTA 2013: Australasian Law Teachers Assocation Annual Conference: law teachers as gatekeepers, 29 September - 1 October 2013, Canberra, ACT, Australia. (Unpublished)

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Abstract

[Extract] When the Uniform Administrative Penalty regime as introduced in 1991, among the most interesting – and puzzling - provisions in the Taxation Laws Amendment (Assessment) Act 1992 were sections 222C and 226K, which introduced the "Reasonably Arguable Position" ("RAP") shortfall penalties, and with it a number of areas of uncertainty and inconsistency.. The RAP provisions are celebrating their 21st birthday in 2013, but show few signs of settling down as they reach adulthood.

Item ID: 32097
Item Type: Conference Item (Presentation)
Keywords: RAP; reasonably arguable position; penalties; tax; income tax; Walstern; Allen; Sent; Carmeron Brae; Traviati; sanctuary Lakes
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Date Deposited: 16 Apr 2014 04:53
FoR Codes: 18 LAW AND LEGAL STUDIES > 1801 Law > 180125 Taxation Law @ 100%
SEO Codes: 94 LAW, POLITICS AND COMMUNITY SERVICES > 9499 Other Law, Politics and Community Services > 949999 Law, Politics and Community Services not elsewhere classified @ 100%
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