The Stages Of Ericksons Theory Of Erik Erikson - 837 Words

In this paper I’m going to introduce you to the theory of an ego psychologist called Erik Erikson. Erikson emphasized the role of culture and society and the conflicts that can take place within the ego itself, (. Erik h. erikson). Erikson also believed that as the ego develops people can learn to fix more problems that occur in social relationships. Like Freud, Erikson maintained that personality develops in a predetermined order, and builds upon each previous stage. â€Å"However he did not focus on sexual maturation but rather on the social relationships between children and the childs sense of self Bee, H. L. (1992)†. Erickson can be considered to be one of the great psychologists of the 20th century and his popularity can be â€Å"derived†¦show more content†¦The second of the eighth stage, â€Å"toddler or the early child years: comprised of the ages around 18 months to 3 years. â€Å"At this point, the child has an opportunity to build self-esteem an d autonomy as he or she learns new skills and right from wrong. The well-cared for child is sure of himself, carrying himself or herself with pride rather than shame†. During this time of the â€Å"terrible twos, defiance, temper tantrums, and stubbornness can also appear. Children tend to be vulnerable during this stage, sometimes feeling shame and and low self-esteem during an inability to learn certain skills. Eriksons third stage is called, â€Å"Initiative vs. Guilt, this stage happens to preschool age children three to five years old. During this period they experience a desire to copy the adults around us and take initiative in creating play situations. Children make up stories with dolls, toy phones and miniature cars, playing out roles in a trial universe, experimenting with the blueprint for what they believe it means to be an adult. Children also begin to use the word why according to Gould, M. A. (2015) .† The fourth stage occurs during childhood between the ages of five and twelve and is called Industry vs. Inferiority . It is at this stage that the child’s peer group will gain greater significance and will become a major source of the child’s self-esteem. The child copes with new learning and social demands. At these ages success leads to a sense ofShow MoreRelatedStages of Development: Erikson vs. Freud1466 Words   |  6 Pagesin stages, which are called â€Å"Psychosexual Development Stages.† In 1950 Erik Erikson developed â€Å"Psychosocial Stages,† which are greatly influenced by Freud’s theories. Freud’s theory centers on psychosexual energy or the libido. Erickson’s theory centers on issues and tasks being met at specific ages. Even though we are sexual beings, our developmental stages do not focus entirely on sexual pleasures. Both theories do show that personality develops in stages. Although, Erickson’s theory isRead MoreInfluential Educators And Education Program1136 Words   |  5 Pagesaround today. Erik Erikson Another influential educator would be Erik Erikson by developing his own theory of education. On June 15, 1902 Erik Erikson was born in Germany. Anna Freud greatly impacted Erickson’s life (Cherry, 2015, para. 2). Erickson’s theory consists of 8 stages of an individual person. His theory was propelled by his own wonders of life development of humans (Cherry, 2015, section 3, para. 2-3). According to Wendy Sharkey (1997, section 2) these are the stages and occurrencesRead MoreJean Piaget And Erik Erikson Essay1187 Words   |  5 PagesBoth Jean Piaget and Erik Erikson were great Theorists, that works help us understand children’s thought processes and skill sets. Teachers are interacting with their students based on developmental and skill age-appropriateness, while incorporating foundations of theorist teachings. A child-theorist’s research can provide an understanding of how and why children behave, as well as how they process information. Erik Erickson ’s 8 Stages of Development provided a timeline for stages people’s minds goRead MoreEssay on Freud V Erickson1371 Words   |  6 PagesEventually, Freud set up a private practice in the treatment of psychological disorders, which gave him much of the clinical material on which he based his theories and his pioneering techniques.(Amacher) Freuds theories of development relied heavily on the belief that infantile sexuality must be seen as an integral part of a broader developmental theory of human personality. This had its origins in, and was a generalization of, Breuers earlier discovery that traumatic childhood events could have devastatingRead MorePersonifying Eriksons Theory Essay872 Words   |  4 PagesErikson’s Theory Erik Erikson was a prominent American psychologist that created many theories about human development and social growth. Erikson produced a stage model based upon the premise that a person lives in the social world and that personality is formed based upon the social interactions that a person experiences. He describes a series of development crises that a person must face throughout the lifespan. Erikson’s theory can be applied to â€Å"The King of Pop†, Michael Jackson. Many stages of Erikson’sRead MoreErik Erikson Was An Ego Psychologist Who Emphasized The1607 Words   |  7 PagesErik Erikson was an ego psychologist who emphasized the role of culture and society and the conflicts that can take place within the ego. He developed a theory of psychosocial stages where he believed a crisis occurs at each of the eight stages of development. Erik Erikson was influenced by Sigmund Freud, who emphasized the conflict between the id and the superego, but unlike Freu d, Erikson believed that the ego develops as a result of successfully resolving crises in eight distinct stages thatRead MoreIntroduction. Erik Erickson’S Interest In How One’S Environment1646 Words   |  7 Pages Introduction Erik Erickson’s interest in how one’s environment and social interaction drives human behavior and the development of personality, led him to create the psychosocial theory, â€Å"Eight Stages of Man.† Erikson’s final four stages of psychosocial development describes a person’s development from adolescence to late adulthood. This paper will analyze the final four stages of development, which includes: Adolescence, Young Adulthood, Middle Adulthood, and Late Adulthood. However, one of theRead MorePsychoanalytic Theory Vs. Erick s Psychosocial Theory938 Words   |  4 PagesFreud’s Psychoanalytic Theory vs. Erick’s Psychosocial Theory Many follow the theories of ether Freud’s or Erickson’s that the use of development is through a variety of stages throughout life. People may believe in one over the other as they are both different theories. While Sigmund Freud, a Viennese physician who is well known for his revolutionary ideas on psychology and psychiatry, but also on Western thought in general. He states that If electronic media were hazardous to intelligence, theRead MoreErick Erickson A Psychoanalytical Perspective on human development2657 Words   |  11 Pages Erickson’s Psychoanalytical Perspective on Human Development Final Project Paper Excelsior Community College Tatiane Boyd 4/19/15 This paper was prepared for PSY 235, Lifespan Development. Abstract The growth and development happening throughout a human’s life have been divided into five broad categories including infancy, childhood, adolescence, adulthood, and aging. However, in accordance with Erick Erickson, human development happens in eight different psychosocial stages. AndRead MoreErik Erikson s Stages Of Development1608 Words   |  7 Pages The Psychosocial Development The View on Erik H. Erikson s Stages of Development Frank Phan Cosumnes River College Psychology 300 Abstract This paper will touch over the aspects of Erik H Erickson s eight stages and how they affect everyday lives from infancy to adulthood. The paper will go over the approximate ages and the psychosocial crisis that they will eventually come to. Neglecting a child can lead to a cause of mental negligence in the form of Arrested Development. Within different

Privatization of American Prisons a System for Profit Essay

Abstract The subject of this paper will be a compilation of research on the privatization of American prisons. This will include the reasons for, the historical aspects of, and the ethical and legal problems that it can and has caused. The research methods that will be used to develop this research paper will be done through both classical use of books and use of internet-based sources. This topic is important for analysis because the privatization of American prisons is a subject that raises many ethical and legal questions on its legitimacy and effectiveness as a means of correction. One believes that the findings of this paper will show that privatization of American prisons is for the most part an ineffective means to run prisons†¦show more content†¦This type of ownership and management of prisons, though not new, only began again in recent history in the 1980s. The reasons for this development of private prisons are threefold and these three trends converged in the 1980s: the i deological imperatives of the free market, the huge increase in the number of prisoners, and the increase in imprisonment costs (Smith, 1993). In this Reaganite era it seemed that private enterprise could do any job the government had been doing cheaper and more efficiently, including running prisons. The first trend of ideological imperatives began in the late 1950s and continued to grow into the late 1970s as the public lost trust in the government. It is estimated that public trust of the government in this era declined from 80 percent in the 1950s to 33 percent by the late 1970s (Logan, 1990). This lack of trust in the government allowed for the ideological movement toward privatization. The problem with this ideological desire to take prisons away from the government and turn them over to private corporations is the basic fact that the government is the one that sentences people to prison and should be the one responsible for taking care of these inmates. By turning this care over to private corporations an ethical and legal nightmare can and has developed. The second trend of increasing numbers of inmates was rooted in a new toughness on criminalShow MoreRelatedPrivatization of American Prisons1661 Words   |  7 Pagesrunning prisons out of the hands of state and federal authorities and contracting it out to private organizations. Along with the drift to privatization is a plethora of research pertaining to the subject taking many different approaches to analyzing the effectiveness. The majority of research focuses on one of three areas. The first questioning whether or not it is cost effective to make the switch. The second being the ethical problems that can and have risen from the privatization of prisons. TheRead MoreSheding the Light on the Privatization of Prisons from the Costs Point of View1102 Words   |  5 Pages In 2013 a paper from authors, Kish and Lipton discuss the title: Do private prisons really offer savings compared with their public counterparts? The purpose of this article is to shed light on the privatizat ion as far as the cost savings. The authors point out the key points of cost saving are: The construction of a private prison is typically faster since voter approval is not required. The reduction of staff members is one way of reducing cost. The author states the problem being, the measurementRead MorePublic Facilities And Private Prisons1116 Words   |  5 Pages Prison is an institution designed to securely to house inmates who have been convicted of crimes. The United States holds the records for having the largest inmate population residing within the walls of the correctional system. The inflation in correctional spending and the largest prison population have impelled lawmakers and the government to look toward the privatization of prisons. Privatization of prisons is the use of private sector or corporation in financing, constructing, andRead MorePrivate Prisons Are Becoming A Cash Cow For A Lot Of Mega Corporations For Big Business1035 Words   |  5 PagesPr ivate prisons are becoming a cash cow for a lot of Mega Corporations for big business. At one time in American penal system operated at dangerous criminal needed to be put under lock and key in order to protect society. Now and days many of our states are trying to save money so that’s why private prisons have been the answer to a lot of these states. We as a country are moving to that direction because it’s easier on states. With public prisons overcrowded the move for states to privatize prisonsRead MoreAmerican Incarceration : Where We Are, And What Can Be Done?1518 Words   |  7 PagesVargas UGS 303 Mass Incarceration 5 October 2015 American Incarceration: Where We Are, and What Can be Done From its early inception as a necessary aspect of modern society to its broken state that can be seen today, the American penal system has changed radically in recent history from an institution that performed the duty of safeguarding the public from those too dangerous to be left unsupervised to a business model concerned more with generating a profit for shareholders. With a 500% increase in inmatesRead MorePrivatization Of A Capitalist Society1699 Words   |  7 PagesA criminal is easier to deal with when they’re found dead. A living criminal must be tried in court of their peers, provided legal representation, and then must have whatever prison time they receive - if any - paid for by the Government. Meanwhile a dead criminal just needs to be acknowledged then buried. When it comes to dealing with live criminals, a government finds itself in a position where it must provide for the safety and wellbeing of members of society that are often ignored, which canRead MoreA Bri ef Note On Academic And Professional Communications1471 Words   |  6 Pagesand state run facilities, however, as the privatization of correctional facilities became more prevalent, so too did instances of corruption. As more federal and state run institutions became privatized there was a marked increase in numbers of those incarcerated as well as a push for more stringent sentencing of those convicted of committing a crime. This has resulted in those companies responsible for running these facilities taking advantage of a system originally set up to house those convictedRead MoreIs Prison Privatization Really a Long Term Fix? Essay1698 Words   |  7 PagesPrison Privatization is a term used for which local, state and federal correction facilities hire companies from the private sector to run prisons and provide prison-related services. Some private companies are contracted only to provide things such as medical care, counseling, food services, and maintenance within publicly o wned jails and prisons. Today, more and more private companies are being contracted to not only design and build, but also to operate new jails and prisons on both the stateRead MoreThe Prison System Of America1052 Words   |  5 PagesThe â€Å"Prison Industrial Complex† was a term that was used by anti-prison activist within the prison abolishment movement to argue the attendant interest of prison industrialization, and t development of a minority prison labor force (Davis, 2003). This giant prison enterprise is an essential component of the U.S. economy, and has as its purposes such as profit, social control, and an interweaving of private business and government. These giant financial institutions recognized that prison buildingRead MorePrivate Prisons1166 Words   |  5 PagesRunning head: PRISON PRIVATIZATION 1 An Assessment of Prison Privatization Sharon Baumann-Heller ORG 8575 Michael Mills August 12, 2012 PRISON PRIVATIZATION 2 Abstract Over-crowding in our federal, state, and local prisons, along with a depressed economy, has resulted in a trend toward privatization of these facilities. This paper examines the core issues surrounding private prisons in the areas of cost-effectiveness, recidivism

Genuine Use Of The Complying Conditions †Myassignmenthelp.Com

Question: Discuss About The Genuine Use Of The Complying Conditions? Answer: Introducation The issue of tax-avoidance is like a double-edged sword in the hands of the tax authorities. It becomes difficult, for both the taxpayers as well as the authorities, to differentiate between the genuine use of the complying conditions and the actual compliance of the regulations. In certain cases, a taxpayer may put forth a tax-avoidance proposal as a non-tax avoidance proposal to escape the tax net. In some cases, this happens because the margins from investments are too low for the taxpayer. However, when a taxpayer is opting for a better rate of return by investments not being subject to taxation because of tax avoidance use of the Act, then the purpose of the taxpayer is to take undue advantage of tax avoidance regulations. In the view of the Commissioner, this is also shown through the lawsuit of Challenge (CA) and is also consistent with the approach which the Australian High Court adopted in the case of Federal Commissioner of Taxation v Spotless Services Ltd (1996) 186 CLR 404. Even McGechan J has also spoken about how such an arrangement was structured in the case of Elmiger (HC)[1], and I quote: I am quite unable to accept submission (a). Clearly, and at the very least, one of the purposes or effects of the downstream transactions was tax avoidance, and that was not a merely incidental purpose or effect. One need not look very far. There was, of course, an ordinary business purpose or a degree of ordinary business purpose in what was done. Fay Richwhite and CML intended to make profits. That is true in all business, including business carried forward in a tax effective way: it is not done for amusement or to tantalise the tax man. They went about it, however, in a way which - tax factors apart - was extraordinarily and unnecessarily complicated. There was no reason - tax factors apart - for the elaborate downstream chain and auxiliary activities being included in something which in essence was a lending of money raised by the RPS transactions on secure investments earning interest. To say otherwise is like travelling from Wellington to Auckland through Stewart Island, the Ch athams and Kermadecs (if not Easter Island), then claiming that is just another available route. Unquote. In view of such observations, it follows that the size of a tax benefit achieved by a taxpayer under the structured arrangement cannot be used to establish that the taxpayer has utilised a tax avoidance purpose which is merely incidental. On the contrary, taxation authorities need to put forward a strong evidential factor in a court of law which will make the judge consider a view on whether the tax avoidance purpose of the taxpayer is following naturally from a non-tax avoidance purpose. Merely saying that the tax benefits are large, can make it difficult for the taxation authorities to establish that the taxpayers tax benefits shall follow naturally from or maybe necessarily linked to, some other purpose[2]. The issue which this paper claims to look into is the task faced by the taxation authorities in identifying any arrangements which are structured by the taxpayer and this includes identification of the tax effects under the tax provisions covering the issues[3] through Sections BG 1 and GA 1 of the Income Tax Act of 2007. Regulations s 108 of the Land and Income Tax Act, 1954; s 99 of the Income Tax Act, 1976; ss BG 1 and GB 1 of the Income Tax Act, 1994; ss GB 1 and GB 1 of the Income Tax Act, 2004; ss BG 1 and GA 1 of the Income Tax Act, 2007; s YA 1 of the Income Tax Act, 2007. Ben Nevis Forestry Ventures Ltd v Commissioner of Inland Revenue [2008] NZSC 115, [2009] 2 NZLR 289. BNZ Investments Ltd v Commissioner of Inland Revenue (2009) 24 NZTC 23,582 (HC). Commissioner of Inland Revenue v Alcan New Zealand Ltd [1994] 3 NZLR 439 (CA). Commissioner of Inland Revenue v BNZ Investments Ltd [2002] 1 NZLR 450 (CA). MacNiven (HM Inspector of Taxes) v Westmoreland Investments Ltd [2001] UKHL 6, [2003] 1 AC 311. Penny v Commissioner of Inland Revenue [2011] NZSC 95, [2012] 1 NZLR 433. Sovereign Assurance Company Ltd v Commissioner of Inland Revenue [2012] NZHC 1760, (2012) 25 NZTC 20-138.APPROACH TO SECTION BG 1 Before we start the discussion on matters related to tax avoidance by taxpayers, we need to understand the explanation which Section BG 1[4] provides: a tax avoidance arrangement structured by the taxpayer becomes void as it gets against the viewpoint of the Commissioner; in such cases the Commissioner has the option to counteract the tax advantage which the taxpayer has obtained under the arrangement. Under the legislation, there are certain key elements which apply to ss BG 1 and GA 1 of the Income Tax Act, 2007: arrangement; tax avoidance; and tax avoidance arrangement. Section BG 1 is used by taxation authorities to explain the term tax avoidance arrangement. This term contains two important parts - the term tax avoidance and arrangement. We will discuss the term arrangement first and the term tax avoidance will be discussed later. The concept of an arrangement is defined in s YA 1 as a means or an agreement or a contract or a plan or an understanding, which may be enforceable or unenforceable and includes all the steps as well as the transactions through which it can be brought into effect. Definition of the term arrangement had been provided in s 99(1) of the Income Tax Act, 1976 and was considered by Richardson P in the case of BNZ Investments No 1 (CA) and it differs from the current definition of arrangement in s YA 1[5]. The term is defined under s YA 1 as an arrangement can be a contract which is legally enforceable or a less formal agreement or a plan which may or may not be legally enforceable. Although the words used in the above noted definition, an agreement, contract, plan, or understanding have been used in the singular form, it does not convey the meaning that the arrangement structured by the taxpayer would be located either in a single document or transaction. This makes it clear that there can be two or more documents or may be transactions, which may together make one arrangement. This has been established in the case of Tayles v Commissioner of Inland Revenue [1982] 2 NZLR 726 (CA), where the appellant farmer had executed three documents a deed of trust, a deed of partnership and an agreement for the transaction which involved only one stock. Therefore, the definition of the term makes it clear that an arrangement can be encompassed of various actions which have been undertaken by the taxpayer for carrying out a structured arrangement, even if all the actions are not delineated in the agreement or contract or plan or understanding. This is also established in the case of Commissioner of Inland Revenue v Penny [2010] NZCA 231, [2010] 3 NZLR 360, where Randerson J stated, and I quote: I am satisfied that an arrangement is not limited to a specific transaction or agreement but may embrace a series of decisions and steps taken which together evidence and constitute an agreement, plan or understanding. Any such arrangement may be continued in each of the income years in question or may be varied from year to year. Unquote. In some other decisions, the courts did convey the meaning that two or more transactions may not be sufficiently linked to each other so that they can constitute an arrangement. These decisions were instrumental in suggesting that two or more transactions cannot be regarded as constituting an arrangement just for the reason that one person is proved to be the party to both transactions and it has been assumed that he entered into one transaction because of the other. When such happenings come to the forefront, it is for taxation authorities to collect and examine all the relevant facts pertaining to the transaction or transactions and present their linking with the structured arrangement developed by the taxpayer and present the actual facts to the court. In this context, the first step was taken by Wild J while dealing with the case of BNZ Investments No 2 (HC)[6], when he undertook an extensive analysis of the presented facts before he considered the application under s BG 1. It sometimes become difficult even for the honourable judges to take a decision as to what is relevant when analysing whether there is a genuine tax avoidance by the taxpayer or whether any tax avoidance is being shown as merely incidental to the non-tax purpose. In short, it is the correct analysis of the information which will be relevant in reaching to a fair and accurate viewpoint as to whether there is a tax avoidance, if it can objectively establish the commercial an d economic reality of the transactions and can relate the structured plan of the taxpayer to a particular section of the Act. Similarly, the collected information will also become relevant to the test not merely incidental, if it leads to the evidence of a non-tax avoidance purpose of the taxpayer which can explain the exact structure of the arrangement proposed by the taxpayer[7]. In this context, the present case of Mr. Nathan can be compared with that of AMP Life Ltd v Commissioner of Inland Revenue (2000) 19 NZTC 15,940 (HC). This case is considered to be an authority on the subject that the sequence of the reported events may not always constitute an arrangement merely on the consideration that one event follows the other and/or they seem to be causally related to each other. The contention of the Commissioner was that in this case, there was an arrangement between AMP and AFS (a subsidiary) and this was surmised because of the following related steps: AMP and various subsidiaries of it (including AFS) were grouping their losses which they had incurred because of the share market crash of 1987 and were claiming deductions on account of these losses in their income year ended 31 March 1988; AMP had subscribed for capital in AFS in December 1989; AMP had sold its shares in AFS to another subsidiary, AMP Discount Corporation in October 1992; and AMP was claiming deduction on account of loss it suffered on the disposal of the AFS shares. This was concluded as artificiality and contrivance by the Commissioner while presenting its case to the court on the surmise that it also indicated of an arrangement which was structured by the management of AMP so that the tax purpose could be contrived and they could make it to appear as if all these transactions were incidental to the commercial purpose of the company. In his final judgment, Learned Woodhouse P made the following point in Challenge (CA) and I quote: As a matter of construction I think the phrase merely incidental purpose or effect in the context of s 99 points to something which is necessarily linked and without contrivance to some other purpose or effect so that it can be regarded as a natural concomitant. Unquote. In this instance, the artificiality and contrivance were merely relevant and incidental to the test because, as observed by the honourable court, if artificiality and contrivance are used for achieving the purpose of tax avoidance, then there is every likelihood that tax avoidance should be considered as an end in itself rather than merely being incidental to another purpose. Woodhouse P in Challenge (CA)[8] also commented on this relevance of artificiality or contrivance to the merely incidental test, and I quote: When construing s 99 and the qualifying implementations of the reference in subs (2)(b) to incidental purpose I think the questions which arise need to be framed in terms of the degree of economic reality associated with a given transaction in contrast to artificiality or contrivance or what may be described as the extent to which it appears to involve exploitation of the statute while in direct pursuit of tax benefits. To put the matter in another way, there is all the difference in the world, I think, between the prudent attention on the one hand that can always be given sensibly and quite properly to the tax implications likely to arise from a course of action when deciding whether or not to pursue it and its pursuit on the other hand simply to achieve a manufactured tax advantage. Unquote. There are other purposes or effects connected with arrangements and identifying them leads to making the distinction between tax avoidance and non-tax avoidance purposes of the arrangement that become an integral part to the structured arrangements made by taxpayers. The experts state that there is a commercial objective for which the stakeholders try to maximise their financial returns from their profitable trading transactions. However, the stakeholders financial returns from their profitable trading transactions get improved only when there is tax which they avoided to pay under the arrangement. When only the merely incidental test is considered, the non-tax avoidance purpose should be able to explain why the taxpayer made an arrangement which was structured in that particular way. When considering these facts, the purpose of the taxpayer in providing the arrangement in a way and structured in a particular way so that it helps in the tax avoidance purpose or effect through the use of this particular structure is not sufficient enough to prove that it was merely incidental to any non-tax avoidance purposes or effects[9]. Outcome To arrive at a clear understanding of the facts related to the case of Nathan in this case study, it is essential to know how the arrangement interacts with the Act. This will also lead us to the subsequent analysis of the arrangement structured by Nathan through which we can identify the additional relevant provisions and which will lead us to those tax effects which are required to be understood. Sometimes, a taxpayer, such as Nathan, will have put forward a very general purpose to explain his structured arrangements and it is for the taxation authorities to how to treat such purposes in the context of the merely incidental test. If s BG 1, combined with the merely incidental test, is applied to this specific arrangement which Nathan has entered into, Learned Woodhouse P would consider whether a tax avoidance purpose is merely incidental by considering by reference to the arrangement itself. Although the existence of such a purpose may not be sufficient for establishing a tax avoidance purpose, it is required that more information, which is merely incidental to it and which leads to the adoption of a particular structure by Nathan, would be required before an assessment can be made whether the tax avoidance purpose of Nathan is merely incidental to a more specific non-tax avoidance purpose. References Enonchong, N.D. Undue Influence and Unconscionable Dealing (Sweet Maxwell 2006) Mayer, D.N. Liberty to Contract: Rediscovering a Lost Constitutional Right (Cato Institute 2011) Poole, J. Contract Law (OUP 2008) Trebilcock, M.J. The Limits of Freedom of Contract (HUP 1993) Ben Nevis Forestry Ventures Ltd v Commissioner of Inland Revenue [2008] NZSC 115, [2009] 2 NZLR 289. Challenge Corporation Ltd v Commissioner of Inland Revenue [1986] 2 NZLR 513 at 555 (PC). Commerce Commission v Fonterra Co-operative Group Ltd [2007] NZSC 36, [2007] 3 Elmiger v Commissioner of Inland Revenue [1966] NZLR 683 (SC) at 687688. Furniss (Inspector of Taxes) v Dawson [1984] AC 474 (HL). Miller v Commissioner of Inland Revenue [1999] 1 NZLR 275 (CA). Penny v Commissioner of Inland Revenue [2011] NZSC 95, [2012] 1 NZLR 433. W T Ramsay Ltd v Inland Revenue Commissioners [1982] AC 300 (HL). [1] Elmiger v Commissioner of Inland Revenue [1966] NZLR 683 (SC) at 687688. [2] (see Hadlee (HC); Westpac). [3] (see Ben Nevis and Westpac) [4] ss BG 1 and GA 1 of the Income Tax Act, 2007 [5] s YA 1 of the Income Tax Act, 2007. [6] W T Ramsay Ltd v Inland Revenue Commissioners [1982] AC 300 (HL). [7] AMP Life Ltd v Commissioner of Inland Revenue (2000) 19 NZTC 15,940 (HC) [8] Challenge Corporation Ltd v Commissioner of Inland Revenue [1986] 2 NZLR 513 at 555 (PC). [9] Mayer, D.N. Liberty to Contract: Rediscovering a Lost Constitutional Right (Cato Institute 2011)