Burdeno Proof

FCT v Liang: Full Federal Court reaffirms taxpayer burden of proof

FCT v Liang: Full Federal Court reaffirms taxpayer burden of proof

The Full Federal Court case of Commissioner of Taxation v Liang [2025] FCAFC 4 serves as a reminder that when challenging an ATO decision at a court or tribunal, it is the taxpayer who carries the burden of proving that an assessment is excessive and what the assessment should have been.