【正文】 b. workers’ pensation payments for loss of ine。 c. “Mutual payments”. Capital Receipts Our system was designed to tax “ine”. The concept was based on the trust law distinction between capital and ine (the “tree” and the “fruit of the tree” analogy) . Capital receipts were not taxed (and still are not taxed) UNLESS the are covered by the CGT provisions Windfall Gains Windfall gains fall into two main categories: a. Gambling winnings。 f. gambling winnings。 – Ine from carrying on a business. ? The ITAA also deems some receipts to be “ine” for taxation purposes (eg noncash business benefits, tips and gratuities, post1985 capital gains etc). These receipts are called ‘statutory ine’。 – Deemed dividends (various sections incl Div 7A)。 k. a loan from a private pany to its managing director。 4. If the taxpayer relies upon the receipt it is more likely to be ine。 b. Under s 2654 and s 11038 – illegal activity outgoings。 c. the receipt is partly assessable because it es from the general trading activities of the club which cannot be sourced to members alone. Question: The Cardwell Quoits Club was established in 1980 to promote quoits in the upper Herbert. Members pay an annual fee which was used to rent premises and finance the club’s activities. To allow ‘fellowship’ after practice or petition matches a refrigerator was bought and the club sold drinks and snack foods to members and guests. As quoits gained in popularity, membership increased, the club purchased new premises, installed a bar and (later) a restaurant – again for members and guests. The restaurant was also rented out for weddings and other functions. With its increased size the club also installed poker machines and added 10 motel units. The club now has a membership in the thousands and regularly serves a diverse range of visitors from all over Australia. What is its tax position? Should Be Received by the Taxpayer as Ine Two points: 1. The receipt must be an “ine receipt” in the hands of the taxpayer。 and c. s 21A (which deals with “noncash business benefits). Question: Which, if any, of the followi