Inside the $164-million calculation
The Case File
Inside the
$164-million
calculation
The Integrity Commission says Dr Andrew Wheatley’s identified uses of money exceeded the lawful income and financing it could verify. Wheatley says legitimate rental income and business funds were ignored. We follow the numbers, the evidence and the gaps between the two accounts.
$164M
What this case is about
A forensic dispute, not a simple allegation and denial
Investigators compared money they could identify as lawfully available to Wheatley with assets, spending and other uses of funds. Their calculation produced an alleged shortfall of about $164 million.
Wheatley says the analysis is false, inaccurate and unfair because it failed to recognise approximately $168 million in rental income, lawful sources used to repay about $50 million in business loans, and other legitimate proceeds.
The Integrity Commission says verified rental income and other accepted explanations were already credited before the final figure was reached.
− verified lawful sources
≈ $164 million
This is a source-and-application-of-funds analysis. It is not an allegation that $164 million was stolen from the State.
1. Investigators identified sources
These included employment and parliamentary earnings, rental income, loans, investments, property-sale proceeds, business income and other funding that could be verified.
2. They identified applications
These included property purchases, investments, loan payments, estimated living expenses, other expenditure and increases in assets.
3. They revised the model
The report says explanations it considered satisfactory, deposits it independently verified and some transactions showing consistent patterns were credited to Wheatley.
4. A gap remained
The Commission concluded that identified lawful sources still fell about $164 million short of the uses of funds over the relevant period.
The numbers
Four figures that should not be confused
Approximate deposits reviewed across four personal bank accounts. This was not the amount alleged to be illicit enrichment.
The approximate deposits the Commission said remained unexplained after adjustments and credits.
The amount Wheatley now says he lawfully earned in rent and supported with leases and bank documentation.
The Commission’s estimated difference between verified lawful sources and identified uses of funds.
Claim versus record
Open the forensic ledger
Each dispute has three parts: Wheatley’s explanation, the Commission’s finding and the evidence still needed to reconcile them.
Rental income
Approximately $168 million in lawful rent was supported by leases and bank records but not properly recognised.
Wheatley reported $143.3 million in rental income. Investigators requested tenant, lease, payment and bank evidence, received leases for only some properties and credited rent they could verify.
Which exact deposits were accepted, rejected or already included? Why do the rental totals differ?
About $50 million in loans
Lawful and verifiable sources used to repay business loans were not properly considered.
Several loans were also liabilities that should have appeared in statutory declarations.
Were all proceeds and repayments correctly traced? Even if repayment was lawful, were the liabilities disclosed?
Six apartments described as gifts
The units represented his 30 per cent share of a property joint venture. Lawyers described the transfers as gifts, but they were commercial compensation.
Investigators already considered that explanation. Their concern extended to the disclosure of interests in all 20 lots and the later disposal of 14.
When did the ownership interests arise, how were the 14 other units disposed of and who received the proceeds?
Prosperity Realtor and the Stilwell property
The media statement does not directly answer this finding.
A payment described as a land down payment should have been reported as an investment in the company that owned the land.
What was Wheatley’s shareholding, where was the investment disclosed and did it generate returns?
Western Medical Centre
His lawful business activities included the sale of his former ownership in a medical complex.
The reported proceeds could not be adequately verified from the records supplied or independently obtained.
A sale agreement, proof of payment, bank records, tax treatment and purchaser confirmation would help settle the issue.
Failure to provide information
He cooperated and investigators could have requested any further evidence they required.
It made repeated written requests and concluded that some information required by the Director of Information and Complaints was not fully provided.
What precise information remained outstanding, and does later submission cure an earlier failure?
The 20-property question
Six units were transferred to Wheatley. What happened to the other 14?
The report says land was subdivided into 20 lots registered jointly to Wheatley and business partner Patrick Phipps. Six were later transferred into Wheatley’s sole name. The remaining 14 were divested while he remained a joint owner, according to the Commission.
Fourteen units the Commission says were divested
Wheatley’s statement explains why he received six apartments. It does not provide a detailed public account of the sale or transfer of the other 14, the distribution of proceeds or how those interests appeared in his declarations.
What each side says about the same evidence
He says the Commission did not properly recognise lawful rental income and business financing, and that he can prove every dollar and asset was acquired lawfully.
Summary of media statement, June 17, 2026
The report says accepted explanations, independently verified deposits and legitimate rental income were credited before approximately $168 million in unexplained deposits and a $164-million overall gap remained.
Summary of investigation report
Test the disputed figures
This illustration shows how the alleged gap changes when additional income is entered. It does not reproduce the Commission’s full forensic model.
Important: some rental income may already have been counted by investigators. Only income proved to have been omitted should be added. A figure below zero would not itself establish that the Commission’s complete model is wrong because other disputed classifications and expenditure assumptions may remain.
Three documents, three different roles
The public record is made up of an investigation, a prosecutorial decision and Wheatley’s response. None should be read in isolation.
Investigation report
Sets out the financial analysis, alleged omissions, evidence gathered and the Director of Investigation’s conclusions.
Indicative ruling
Records the Director of Corruption Prosecution’s decision that four charges should be brought.
Wheatley’s statement
Rejects the findings and identifies rental income, loans and business transactions as central to his defence.
Five years of notices, records and responses
The matter is referred for investigation. Company, land, tax and parliamentary records are sought.
Wheatley attends an interview with his attorney. Further interviews are postponed or rescheduled amid requests for more information.
Investigators seek bank records and information concerning companies, investments and related entities.
Wheatley receives an illicit-enrichment notice and is asked to explain sources of funds. Property, tax and financial records continue to be collected.
The source-and-application analysis is repeatedly updated. Wheatley, his attorney and accountant meet investigators and provide additional submissions.
Additional third-party records are obtained. The report and an indicative prosecutorial ruling are submitted to Parliament.
Four charges indicated
The Director of Corruption Prosecution determined that Wheatley should be charged with the following offences:
The missing reconciliation
The case turns on evidence, not which statement sounds more convincing.
The Commission says the $164-million estimate remained after verified income and accepted explanations were credited. Wheatley says legitimate rent, financing and business proceeds were improperly excluded.
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