Lewski v Commissioner of Taxation, [2017] FCAFC 145

obligation to pay purchase price was incurred on agreement date rather than subsequent closing

an alternate resolution that the taxpayer was not entitled to an income distribution if Revenue denied a trust deduction made her entitlement contingent and non-includible

since the taxpayer through her husband as agent had knowledge of an income distribution, her subsequent purported disclaimer was not immediate

a trust income declaration that was subject to a tax contingency did not result in an income inclusion to the beneficiary

knowledge of agent imputed to principal