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Edited version of your private ruling
Authorisation Number: 1012554875506
Ruling
Subject: Deduction for mattress
Question
Are you entitled to a deduction for the costs of a mattress?
Answer
No.
This ruling applies for the following period
Year ended 30 June 2013
The scheme commenced on
1 July 2012
Relevant facts
You are an employee and carry out night shifts.
Your employer provides beds but these are too firm for you and cause you pain.
You purchased a mattress which is left at work and only used while at work.
Relevant legislative provisions
Income Tax Assessment Act 1997 Section 8-1
Reasons for decision
Section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997) broadly allows a deduction for any losses or outgoings to the extent to which they are incurred in gaining or producing assessable income except to the extent outgoings are of a capital, private or domestic nature.
The courts have considered the meaning of 'incurred in gaining or producing the assessable income'. In Ronpibon Tin NL Tong Kah Compound NL v. Federal Commissioner of Taxation (1949) 78 CLR 47; 56 ALR 785; 8 ATD 431 the High Court stated that
'For expenditure to form an allowable deduction as an outgoing incurred in gaining or producing the assessable income it must be incidental and relevant to that end. The words "incurred in gaining or producing assessable income" mean in the course of gaining or producing such income.'
The expenditure must therefore be related to the production of assessable income.
The purpose of purchasing the mattress was to allow you comfort while you sleep at work rather than in carrying out your duties that produce your assessable income.
Accordingly, the expenses for purchasing the mattress are not deductible because they were not incurred in gaining or producing assessable income and are also private in nature.