the penalty and interest and tax relating to the 80 mil shouldn't be payable as the 80 mil was uncertain income (proof is in the pudding) but the ATO are throwing the book plus some to strengthen their negotiating position. Also the penalties are excessive and are more appropriate for a tax evasion case not an unclear obscure mistake so i think its all a negotiation/scare tactic...
if it goes to court the courts are more reasonable... (more tax payer & shareholder money down the drain)
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