The case was brought against a taxpayer who had participated in athletic events and received payments from grants, sponsorships and appearance fees. The government through the Federal Commissioner of Taxation had sought to compel the athlete to pay tax from her winnings. The taxpayer had insisted that the winnings she got due to her participation in javelin competitions could not be classified as assessable income. The court of the first instance had ruled that all the money Stone had received from her participation in athletics should be classified as assessable income. The taxpayer appealed this ruling to the Full Federal Court to challenge the decision that required her to pay taxes on all her earnings obtained from athletics. The Full Federal Court after conducting its proceedings ruled that Stone was required to pay tax only on sponsorship and appearance earnings.
Stone had argued that the payments she received from sponsorships and appearance fees did not show that she was obtaining regular business income. In addition, her participation in athletics was infrequent and on that basis, she insisted that she could not be treated as a full-time professional athlete by the Commissioner. Therefore, her main intention for participating in such events was not to make profits because she had a full-time job as a police officer. In her arguments, Stone maintained that the decision by the Commissioner to make her pay her taxes was in bad faith because most of the payments she received from her winnings were gratuitous. Therefore, this showed that she was not running a business as stipulated by the law and as a result, this exempted her from paying any taxes on her earnings.
The Commissioner of taxes argued that financial incentives which Stone received from athletics showed that she was involved in a business. The Commissioner argued that the payments were directly linked to contractual obligations she had entered into while taking part in various athletics events. Even though she claimed that her main motivation for participating in javelin competitions was not monetary, she knew that any form of success would bring her financial rewards. Therefore, even though her main purpose for participation was to excel in her sport, the Commissioner argued that she had used her talents to gain an economic advantage. Ultimately, the Commissioner insisted that she had chosen to compete in specific events and as a result, financial rewards obtained through her participation in these events were assessable.
During the Commissioner’s appeal against the Federal Full Court’s decision, the High Court focused on Stone’s intentions to determine if she had a profit-making motive. Even though she did not get income from her activities, Stone used sponsorship funds that were paid to her to further her objectives as an athlete. The court ruled that her participation in athletics activities brought her some financial rewards which were assessable. She had taken part in several endorsements which showed that she was using her athletic ability to get financial rewards which can be categorized as business earnings. In addition, the court ruled that payments from grants and sponsorships which the athlete received were tied to her performance in major athletic events. Even though they were gratuitous, they were still assessable because they were paid according to contractual agreements between event organizers and athletes.