In Deputy Commissioner of Taxation v CCZ26 [2026] FCA 320, Elizabeth Bishop SC and James Parrish, instructed by Samaras Lawyers, represented a taxpayer who had been the subject of freezing orders made in conjunction with the issue of assessments under s 167 of the Income Tax Assessment Act 1936. They also represented three third-party respondents who held property the subject of the freezing orders.

Justice Needham agreed that it was necessary to make suppression orders and pseudonym orders regarding the identity of the parties in order to prevent prejudice to the administration of justice. This was in the particular circumstances where the taxpayer had no opportunity in the recovery proceeding of challenging the s 167 assessments (or the underlying allegations of dishonesty on the part of the taxpayer) and where there was a risk of reputational and commercial harm including to third parties against whom no wrong doing was alleged.

The full judgment may be read here.