Default assessments: the “all or nothing approach”.

The article focuses on the challenges taxpayers face in proving the excessiveness of their assessments in tax appeals, particularly in default assessment cases under s 167 of the Income Tax Assessment Act 1936 (Cth). Topics discussed include the burden of proof in tax appeals, the divergence of opinion regarding the "all or nothing" approach to discharging the burden of proof, and the practical implications of recent Federal Court decisions on this matter.