Sammy works part time for a boutique graphic design consultancy firm close to her home in Flemington, Melbourne. During the year, Sammy was provided with several benefits by her employer. These are listed as follows:

Item	Benefit provided by employer AUD	Allowance tax deduction employee paid AUD
Printer(noteA)	250	250
Air fares(noteB)	3250	Nil
Uni texbooks & other consumables(noteA)	400	400
HELP fees(noteC)	1350	Nil
Taxi/ride share fees(noteD)	620	Nil

Sammy has also collected stamps for close to 40 years. Although Sammy has not acquired any since 19 September 1985, she has over 100,000 stamps in her collection. In mid-2022, Sammy had them valued and to her surprise, they were valued at $1 million in total! Sammy had spent between $5 and $30 on individual stamps through her childhood and teenage years. In October 2022, Sammy decided to sell her collection, and to facilitate this she took a 12-month lease of a pop-up store in a local shopping complex. This cost Sammy $22,000 (including GST). During the period to 30 June, Sammy sold 75,000 stamps and received $1,240,000 in proceeds. The remaining stamps had unfortunately been stolen, when one night the pop-up storage cupboard was broken into. Sammy is awaiting confirmation from her insurance provider as to whether compensation will be received.

Additional Information:

A. The printer enables Sammy to finalise preparation of client briefs from home.

B. The air fares relate to a holiday Sammy went on to Norfolk Island to recuperate after a busy year.

C. Sammy is studying a graphic design course at RMIT University.

D. Sammy on occasion is required to travel home using a Taxi or ride sharing service from her office due to working late and the safety issues this raises.

REQUIRED: Determine the Australian taxation consequences of the above fact situation for the year ending 30 June 2023 by answering the following question set. In doing so, you must show a complete analysis to be awarded full marks, including references to appropriate sources of tax law, presenting all workings and/or explanations.

Question 1: Analyse in depth whether Sammys stamp collection activities may be regarded for tax purposes as carrying on a business, including whether the receipts would be characterised as assessable income and any other potential consequences of your analysis

Question 2: Determine the appropriate tax treatment of the benefits provided to Sammy by her employer, from both the perspective of the employee and the employer