The provisions of Part 7 of the Taxation Administration Act 1999 (ACT) for the collection of tax are not to be interpreted as being subject to considerations of hardship and business convenience. The concept of legal unreasonableness does not give licence to a court on judicial review to assess what might or might not be a reasonable financial imposition upon a taxpayer. The Commissioner may simultaneously pursue multiple enforcement mechanisms (garnishee notices and directors' compliance notices) even where judicial proceedings in relation to one mechanism are on foot. A corporate taxpayer has no entitlement to derive income from trade in circumstances of insolvency, particularly where the insolvency arises from inability to pay a tax liability when it falls due.
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