SDRQ and Commissioner of Taxation (Taxation) [2019] AATA 2003

TAXATION – capital gains tax – disposal of shares in companies – whether a capital gains tax loss occurred – lack of contemporaneous evidence – carry forward capital gains loss – market value of the shares – meaning of 'market value' – transfer not at arm's length – hypothetical purchaser – remission of penalty – recklessness – decision varied

Full decision here