TAXATION -- two appeals under s 14ZZ of the Taxation Administration Act 1953 (Cth) -- where applicant lodged two objections to its income tax assessment for the 2020 income year and where the respondent did not allow the objections -- whether pursuant to s 8-1(1) or, in the alternative, s 40-880 of the Income Tax Assessment Act 1997 (Cth) the applicant may deduct Top-Up Payments which it paid to investors -- whether the Top-Up Payments are on capital account or revenue account -- whether the Top-Up Payments formed part of the consideration paid by the applicant for shares -- consideration of the share sale agreement -- whether extrinsic evidence may be considered to resolve alleged ambiguity in a contract -- consideration of the applicant's business model -- whether the Top-Up Payments were made for the sole purpose of preserving goodwill
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