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Rights and remedies of a taxpayer in the sights of the Commissioner of Taxation: Part 1


This article considers whether anything can be done to preserve a taxpayer's rights long enough for the taxpayer to contest an assessment in the appropriate forum. It outlines the impediments facing the taxpayer to conclude that without reaching an accommodation with the Commissioner, the taxpayer will be in a race to prosecute the Part IVC TAA53 proceedings before the Commissioner seeks to recover the tax debt.

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Rashelle Seiden CTA
As a revenue law specialist, Rashelle focuses on tax litigation, including tax appeals, administrative review, recovery proceedings and tax-related criminal proceedings. In addition, she advises and represents clients in matters concerning administrative law, trusts, corporate and commercial law, bankruptcy and insolvency. Rashelle has appeared in many high-profile cases in the High Court of Australia, the Federal Court of Australia and the NSW Court of Appeal. In 2013, she was appointed Senior Counsel for the State of NSW. Rashelle was listed in the Doyle’s Guide 2016 as a Recommended Taxation Senior Counsel, and a Leading Taxation Senior Counsel in 2017. Rashelle is also a Principal Member, and member of the Appeal Panel, of the NSW Civil and Administrative Tribunal. - Current at 09 February 2018
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