Facts
The taxpayer received a 'Member Superannuation Contributions Surcharge Advice' issued on 15 May 1998 in respect of the year ended 30 June 1997. It was indicated on the notice that it was an 'Advice Only - Do Not Pay'.
The benefit structure type is unfunded defined benefits account according to the Superannuation Contributions Surcharge System (SCS System).
The taxpayer stated in their letter of 30 June 1998 that they received an advance payment for long service leave in June 1997. The taxpayer indicated that this amount has 'inflated' their 'adjusted taxable income' for the purposes of calculating surcharge liability for the 1997 year.
The taxpayer has stated that if it were not for this payment in advance, there would be no surcharge liability in respect of the years ended 30 June 1997 and 30 June 1998.
The taxpayer has asked for a reconsideration of the surcharge liability in view of the above.