On 12 August 2021, the Tax Practitioners Board (TPB) applied to the Federal Court of Australia (Court) seeking civil penalties and a permanent injunction to restrain Ms Van Stroe from providing tax agent services whilst not a registered tax agent within the meaning of the Tax Agent Services Act 2009 (TASA).

On 23 August 2021, the Court ordered until the hearing and determination of the TPB’s application or further order, Ms Van Stroe be restrained from preparing and lodging income tax returns for taxpayers, for a fee or other reward, whilst not a registered tax agent within the meaning of the TASA.

On 3 May 2022, the Court:

1. Declared that on 531 occasions, Ms Van Stroe contravened section 50-5(1) of the TASA by preparing and lodging income tax returns for taxpayers, being the provision of a tax agent service, for a fee or other reward, whilst not a registered tax agent within the meaning of the TASA; and

2. Ordered pursuant to section 70-5(1) of the TASA, Ms Van Stroe be permanently restrained from providing tax agent services (as defined in the TASA) for a fee or other reward, whilst not a registered tax agent within the meaning of the TASA.

On 6 December 2023, the Court ordered, pursuant to section 50-35(2) of the TASA, Ms Van Stroe pay pecuniary penalties to the Commonwealth in the total sum of $230,000 for the contraventions and to pay the TPB’s costs, including reserved costs, to be taxed on a party and party basis if not agreed.

On 18 June 2024, the TPB applied to the Court seeking the imposition of penalties on Ms Van Stroe for alleged contempt of court for breaches of the permanent injunction order made on 3 May 2022, by preparing and lodging income tax returns for taxpayers for a fee whilst not a registered tax agent within the meaning of the TASA, on 233 occasions (First Contempt Application).

On 20 November 2024, the TPB applied to the Court seeking the imposition of penalties on Ms Van Stroe for alleged contempt of court for breaches of the permanent injunction order made on 3 May 2022, by preparing and lodging income tax returns for taxpayers for a fee whilst not a registered tax agent within the meaning of the TASA, on 132 occasions (Second Contempt Application).

On 21 March 2025, the Court made orders that:

1. Ms Van Stroe is guilty of contempt of court for breaches of the permanent injunction order made on 3 May 2022, on the 365 occasions alleged in the TPB's First Contempt Application and Second Contempt Application;

2. For each of the 233 contempts specified in the TPB's First Contempt Application, Ms Van Stroe be sentenced to a four month term of imprisonment, to be served concurrently and commencing on 25 March 2025;

3. For each of the 132 contempts specified in the TPB's Second Contempt Application, Ms Van Stroe be sentenced to an eight month term of imprisonment, to be served concurrently and commencing immediately upon the expiry of the first four month term of imprisonment;

4. That Ms Van Stroe serve the four month and eight month terms of imprisonment consecutively (resulting in a total term of imprisonment of 12 months);

5. That after Ms Van Stroe has served the first six months of the total 12 month term of imprisonment, she is to be released from prison and the remaining balance of the term will be suspended from execution. This is subject to the condition that if the Court determines that she has committed any further breach of the permanent injunction order within a three year period of her release, she will be imprisoned to serve the remaining balance of the 12 month term; and

6. Ms Van Stroe pay the TPB's costs of the First Contempt Application and Second Contempt Application on an indemnity basis, to be agreed or taxed.

Federal Court decisions
Tax Practitioners Board v Van Stroe [2022] FCA 482: https://www8.austlii.edu.au/cgi-bin/viewdoc/au/cases/cth/FCA/2022/482.html
Tax Practitioners Board v Van Stroe (No 2) [2023] FCA 1533: https://www8.austlii.edu.au/cgi-bin/viewdoc/au/cases/cth/FCA/2023/1533.html?context=1;query=482;mask_path=au/cases/cth/FCA
Tax Practitioners Board v Dabalos (formerly Van Stroe) (No 3) [2025] FCA 223: https://www.judgments.fedcourt.gov.au/judgments/Judgments/fca/single/2025/2025fca0223