In a Federal Court hearing on Monday (23 August), legal representatives for the famous Australian actor and his manager John "Strop" Cornell have claimed that the Australian Crime Commission (ACC) has no reasonable grounds of victory in any prospective action which might be launched against the pair.

Hogan, Cornell and their financial adviser, Tony Stewart, are being investigated by the ACC as part of the Wickenby probe into Australian citizens using offshore tax havens.

None of the three men have been charged with any offence and they have all maintained they have no case to answer.

The three men have also asked the Federal Court for up to 1500 documents to be ruled as inadmissible should any further ACC action proceed.

Andrew Robinson, a director with Robinson Legal, confirmed with Lawyers Weekly that this is on the basis of issues related to client professional privilege. Robinson has personally acted for Hogan in the past. He also said that David Rydon, a fellow director with the firm, is the principal lawyer acting on this matter.

"There is obviously a number of disagreements between [our clients] and the Australian Tax Office on a number of issues," Robinson said. "Beyond that, it is too early to comment."

Robinson estimates that any preliminary hearings into this matter could take up to 12 months to reach court.

The ATO believes Hogan used a "residency window" to avoid paying as much as $37 million in tax in Australia between mid-1987 and mid-1991 and from 1994 to 2005.