TAXATION — company of which the defendant was a director failed to remit PAYG as well as owing substantial other sums to the ATO — DPN notice issued to defendant in respect of PAYG withholding — defendant makes payments to the ATO but does not advise until the fifth payment, made at a time that proceedings on the DPN had been commenced, that these were intended to pay his own DPN liability — whether the plaintiff paid amounts for the express purpose of the DPN as claimed
ESTOPPEL — whether estoppel available against the ATO — whether the ATO made representations that the PAYG withholding liabilities had been satisfied — whether there was detrimental reliance — whether the steps the defendant claimed he would have taken but for the representations could in fact have been taken
