Spriggs v Commissioner of Taxation

Taxes and duties – Income tax - Deductions - Appellant taxpayers professional Australian Rules football player and professional rugby league player - Each paid fee to manager for negotiating contract to play with new club - Whether management fee deductible under Income Tax Assessment Act 1997 (Cth), s 8-1(1) as outgoing "incurred in gaining or producing" or "necessarily incurred in carrying on a business for the purpose of gaining or producing" assessable income - Whether each appellant carrying on business exploiting sporting prowess and associated celebrity - Relevance of exclusion from definition of "business" in s 995-1 of "occupation as an employee" - Relevance of Federal Commissioner of Taxation v Maddalena (1971) 45 ALJR 426 2 ATR 541.

Taxes and duties – Income tax - Deductions - Whether management fee not deductible pursuant to s 8-1(2)(a) as an "outgoing of capital, or of a capital nature".

Words and phrases – "business", "incurred in gaining or producing", "necessarily incurred in carrying on a business", "occupation as an employee", "ordinary income", "outgoing of capital".

Income Tax Assessment Act 1997 (Cth) – ss 6-5(1), 8-1, 995-1.