Issue
1
Whether the taxpayer, who knowingly lodges an incorrect tax return because details of a trust distribution are not yet known, is subject to penalty tax under section 226G of the Income Tax Assessment Act 1936 (ITAA 1936) for lack of reasonable care.
2
Whether the General Interest Charge (GIC) imposed under section 170AA (ITAA 1936) should be remitted under section 8AAG of the Taxation Administration Act 1953 (1953).