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This article may be downloaded for personal use only. Permission to reproduce this article must be sought from the Australasian Tax Teachers Association at Curtin University. This article was first published in Journal of the Australasian Tax Teachers Association, 6(1): 133-151, 2011. More information about this journal may be found at http://www.asb.unsw.edu.au/schools/taxationandbusinesslaw/atta/Pages/default.aspx