# Reviewer verdict — bounty-07-hire-purchase-interest-apportionment

> **Reviewer:** Leanne Williamson, Tax Agent (TPB 51194 009)
> **Consent posture:** named (upgraded from initialled on 2026-08-20 per fresh explicit consent, Andrew direct-voice)
> **Consent date:** 2026-08-20
> **Reward paid (AUD):** $550
> **Verdict outcome (from reviewer's §6):** ACCEPT
> **Verdict date:** 2026-07-14
> **PII sweep:** applied (see build script for pattern set); receipts logged in this PR body.

---

---
brief_id: bounty-07-hire-purchase-interest-apportionment
bounty_title: "Hire purchase — interest apportionment"
statutory_anchors: "Div 240 ITAA 1997; s 240-25, s 240-40"
reviewer:
  name: "Leanne Williamson"
  credential_class: "TPB"        
  registration_status: "active"     
  jurisdiction: "Australia"
  attribution_posture: "named"      # upgraded from initialled 2026-08-20 per fresh explicit consent, Andrew direct-voice
  consent_date: "2026-08-20"
reviewed_calculator_version: "copy from brief"  
submission_date: "2026-07-14"           
top_level_verdict: "ACCEPT"            
verdict_hash: ""                 # (we compute this on receipt)
---

# Reviewer Verdict — Hire purchase — interest apportionment

**Bounty:** bounty-07-hire-purchase-interest-apportionment

## 1. Top-level verdict

_Choose one: **ACCEPT** _

- **ACCEPT** — the calculator's statute-to-predicate translation is correct on the facts of the brief. Minor stylistic comments allowed.


**Your top-level verdict:*ACCEPT*

---

## 2. Per-question verdicts

```yaml
per_question_verdicts:
  - question_number: 1
    verdict: "ACCEPT"             
    citation_authority: "section 240.25 ITAA 1997 hire purchase agreement is recategorised as notional loan." 
    reasoning: Notional buyer may be entitled to notional interest on notional loan.
    edge_case_notes: |
      # Optional — anything surfaced by this question worth banking.
  - question_number: 2
    verdict: "ACCEPT"             
    citation_authority: "section 240.50 ITAA 1997 Notional interest is deductible to the extent that would otherwise have been entitled."  
    reasoning: TR 2005/20 deals with interaction of hire purchase and holding requirements for Division 40 depreciation.
      # Free-text reasoning here. Cite where you diverge.
    edge_case_notes: |
      # Optional — anything surfaced by this question worth banking.
  - question_number: 3
    verdict: "ACCEPT"              
    citation_authority: "Section 240.60 ITAA 1997 uses implicit interest rate; i.e. actuarial method of calculation"   
    reasoning: TR 93/16 details when Rule of 78 may be used, which is rare given Division 240 applies to all hire purchase agreements from 27 February 1998.
      # Free-text reasoning here. Cite where you diverge.
    edge_case_notes: |
      # Optional — anything surfaced by this question worth banking.
  - question_number: 4
    verdict: "ACCEPT"              
    citation_authority: "section 240.60(2) ITAA 1997 subtracts both payments made - deposits and payments due to be made i.e. balloon payment. It is thus treated as final principal payment.
    "   # section reference or case citation
    reasoning: |
      # Free-text reasoning here. Cite where you diverge.
    edge_case_notes: |
      # Optional — anything surfaced by this question worth banking.
  - question_number: 5
    verdict: "ACCEPT"             
    citation_authority: " ATO ID 2013/52 deals with GST when a hire purchase agreement is terminated early. Accrued notional interest previously deductible is unchanged.TR 93/16 deals with Rule of 78, only pre 27/2/98 transactions and when financier does not give any detail of how interest is calculated."   
    reasoning: Unearned interest under Rule of 78 unlikely given Division 240 has been in operation for over 28 years
      # Free-text reasoning here. Cite where you diverge.
    edge_case_notes: |
      # Optional — anything surfaced by this question worth banking.
  - question_number: 6
    verdict: "ACCEPT"              
    citation_authority: " Section 240.60 provides method of calculating notional interest
TR 2005/20 covers interaction with Division 40."   
    reasoning: The asset must be wholly or partially used for income producing purposes. 
      
    edge_case_notes: |
      # Optional — Notional buyer should not have an obligation for what the financier reports.
anything surfaced by this question worth banking.
```

---

## 3. Citation audit

_List every statutory section, ATO ruling, or case-law citation the calculator/brief relies on. Mark each: ✓ correct citation / ✗ wrong citation / ⚠ citation exists but is misapplied._

| # | Authority as cited | Your assessment | Notes |
|---|---|---|---|
| 1 |  |  |  |
| 2 |  |  |  |
| 3 |  |  |  |

---

## 4. Edge cases surfaced

_Anything the brief did not cover that you think should be tested by a future revision._

1.
2.
3.

---

## 5. TaxGenii appendix coverage feedback

_Was the pre-loaded statutory appendix (file 05) adequate? What was missing?_

---

## 6. Attestation

I have reviewed this bounty artefact bundle on the facts as presented. My verdict above reflects my professional judgement as at the submission date. I understand my verdict will be minted into the public reviewer registry with the attribution posture stated in the frontmatter.

**Signed:**
**Name:**
**Credential:**
**Date:**