From sladen.com.au: The Full Federal Court case of Commissioner of Taxation v Liang reaffirms that taxpayers bear the burden of proving that an ATO assessment is excessive.

The taxpayers, who argued that their deposits were equity contributions, failed to provide sufficient evidence, leading the Tribunal to side with the Commissioner.

The Federal Court ultimately ruled that the taxpayers did not demonstrate that the deposits were not ordinary income, highlighting the challenges of informal family transactions in tax disputes.