---
review:
  bounty_id: LE-01
  subject_file: div36_for_review.le
  subject_sha256:            # we'll fill this
  statute: ITAA 1997 Division 36 (loss sequencing with net exempt income)
  reviewer:
    name:                    # as you wish it to appear, or leave blank
    credential:              # e.g. CPA / CA / TPB 12345678 / FIPA / LLM (Tax)
    attribution_posture:     # named | initialled | anonymous
  verdict:                   # ACCEPT | FIX | REJECT
  date:
  time_spent_hours:
---

# Verdict — Division 36 loss sequencing rules

**Reviewer instructions:** fill what's useful, delete what isn't. Prose in an email is equally
acceptable — this form exists to keep verdicts comparable, not to constrain you. **A REJECT is worth
the same fee as an ACCEPT.**

---

## 1 — Overall verdict

Pick one and say why in a sentence or two.

- **ACCEPT** — the rules state the law correctly. No changes needed.
- **FIX** — substantially right, but defects listed below must be corrected.
- **REJECT** — the framing or approach is wrong; corrections to individual rules won't save it.

> *Your verdict and reasoning:*

---

## 2 — Findings

One block per finding. Add or delete blocks freely. Ordered by how much they matter, if you can.

### Finding 1

- **Rule / line:**
- **Provision it cites:**
- **Issue:**
- **Consequence** *(what wrong answer does this produce, and when?)*:
- **Confidence:** High / Medium / Low

### Finding 2

- **Rule / line:**
- **Provision it cites:**
- **Issue:**
- **Consequence:**
- **Confidence:**

*(…continue as needed)*

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## 3 — Specific questions we'd like answered

Answer what you can; "didn't check" is a fine answer.

**Q1 — Citation accuracy.** Are the provisions cited correctly identified, in force, and applicable
as described? (ss 6-20, 6-23, 36-10, 36-15(3), 36-15(4), 36-20.)

> 

**Q2 — Completeness.** Is any condition, exception or proviso of those provisions missing from the
rules?

> 

**Q3 — Sequencing.** s 36-10 subtracts net exempt income *inside* the tax loss calculation; s 36-15(4)
subtracts the current-year excess from net exempt income *before* the loss brought forward is
touched. Is that order stated correctly in the rules?

> 

**Q4 — The worked examples.** Scenario `as reported` produces $1,529 carried forward on the ticket
figures. Scenario `if nane` produces $6,108. Scenario `if expenses` produces $2,029. Do those follow?

> 

**Q5 — Unstated assumptions.** What does the file assume without saying so — entity type, residency,
income year, the character of a receipt, anything else?

> 

**Q6 — The dangerous case.** Can you construct a fact pattern where these rules produce a plausible
figure that is *wrong*? This is the question we value most.

> 

**Q7 — Refusal behaviour.** Where the character of the receipt is not stated, the file declines to
produce any carry-forward figure rather than assuming. Is that the right professional posture, or
should it produce a conditional answer?

> 

**Q8 — Readability.** Was any line hard to read as English? Which? (This is a real question, not
politeness — the whole design depends on a practitioner being able to read it.)

> 

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## 4 — Anything else

Including: things we didn't ask about, things that struck you as odd, and any view on whether this
approach is worth pursuing at all.

> 

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## 5 — Administration

- **Attribution.** How would you like to appear in the public reviewer registry?
  `named` / `initialled` / `anonymous`. You can change this later; we default to the more private
  option if you don't say.
- **Payment.** Reply with your preferred method (bank transfer or PayPal) and we'll settle within
  five business days of receiving your verdict.
- **Follow-up.** Are you open to a short back-and-forth if we have questions about a finding?
  Yes / No.

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