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That's very intersting. Good link. Whilst the nuances of 177D are frankly beyond me, it does speak volumes that in 2004 or whenever it was counsel for the ATO differntiated the facts of this situaiton from Hart's and stated that there would be nothing wrong with the facts here. That said...

I havent been following this topic very closely, but on a quick read isnt this very similar economically to Hart's case - which was ruled to fall foul of PtIVA a long time ago. From what I can gather its pretty much the same except that in Hart's somebody packaged the whole thing up nicely...