In February 2021, a consumer purchases the vitamin A supplement and takes just one tablet. He is allergic to avocados and experiences a severe reaction resulting in three weeks of hospitalization. The consumer sues Monsearch Pty Ltd for damages in the tort of negligence and for breach of the product liability labeling rules under Australian Consumer Law. The case takes a considerable time to come to court. Monsearch Pty Ltd, realizing that it may lose the case makes a provision in its financial report for damages of $50,000 and claims this provision as a tax deduction pursuant to S8-1, ITAA97 for the year ended 30 June 2021. The Commissioner of Taxation disallows the deduction. The CEO of Monsearch Pty Ltd seeks your advice as to whether the claim has properly been disallowed. Support your conclusion with references to case law