The risk factor in general for a property investor no doubt rises in a recession but that doesn't mean Delemege (or anyother property developer) is necessarily in trouble.
The ATO going to the court to have Delemege wound up sounds dramatic but it is their (and any reasonably sized business) standard course of action for any slow payer. Why he hadn't paid I don't know (it is strange) but in fairness he may have been considering contesting a matter, he may have been waiting for term deposits to mature?
There are a huge number of variables in determining whether or not Delemege is struggling. What are his debt levels, what terms do the debts have, what is the quality of his assets, how are those assets financed, what reserves does he have etc etc ? We know none of this.
Delemege may well be struggling - I have no idea - but just because he is a property developer & the ATO took him to court 6 months ago (for a debt promptly settled) doesn't mean he is in trouble.
I still consider your posting of that article misleading at best .... I would also be interested in knowing who Penn Health are?