"The dishonest means to be employed with intent to cause that prejudice was the use of statements that the crown says were known to be untrue. Those knowingly untrue statements, the crown says, were directed in the first instance to the taxpayers targeted under the scheme and then through those taxpayers to the Australian Taxation Office and here you will appreciate the Australian Taxation Office is an office that operates under the Commonwealth and when one says 'defraud the Commonwealth', defrauding the Australian Taxation Office is I guess what is really meant by that and amounts to the same thing.
The untrue facts that were to constitute the dishonest means were designed to do a number of things: firstly, to persuade the taxpayer to sign up to the scheme; secondly, to induce those taxpayers to make claims on the Australian Taxation Office for deductions at the rate of $38,000 per unit purchased; thirdly, they were designed to pass on to the promoters or to induce the taxpayers to pass on to the promoters $10,193 from the refunds received.
In the event that the Australian Taxation Office sought to investigate the basis for the claimed deductions the untrue facts were designed to induce those same taxpayers to use those untrue facts to deceive the Australian Taxation Office as to the true factual basis for the deductions claimed.
The prejudice that was intended by the dishonest means involved prejudicially affecting the Australian Taxation Office's ability to protect the property of the Commonwealth and it was designed to prejudicially affect that ability by causing claims to be made by taxpayers for deductions that were based on the false or untrue facts.
They were designed to prejudicially affect the Australian Taxation Office's ability to protect the Commonwealth by putting at risk the ability of the Australian Taxation Office properly to determine whether or not the claimed deductions should be disallowed, that is that the untrue facts were designed to deprive the Australian Taxation Office of a true factual basis for making that determination." (My emphasis).