Catchwords:

TAXATION – income tax – appeal from decision of single judge of the Federal Court– where appellant held forestry interests in a forestry managed investment scheme – where appellant and all other participants held put options over forestry interests – where appellant exercised put options to dispose of forestry interests – whether exercise of put options was a capital gains tax event in relation to forestry interests – whether exercise of put option caused a decrease in market value of forestry interests – whether sale under put option contract was a forced sale – where appellant novated put option sale contract – where appellant retained certain rights under novation deed – whether execution of novation deed was a capital gains tax event in relation to forestry interests – failure to adduce evidence of value of retained rights or circumstances of novation – whether taxpayer established assessment was excessive – appeal dismissed