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Appeal Issues

Appeal Issues (Fuscalite · IV. Analysis) — "At the hearing of this appeal, Mr. Deyab submitted that the critical point in his appeal is the failure of the Tax…

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The appeal concerns the Tax Court Judge’s consideration of the evidence.
At the hearing, Mr. Deyab identified the central issue in his appeal.
The alleged failure was not taking into account all the evidence before the Judge.
The central issue will be examined through three issues identified in Mr. Deyab’s memorandum of fact and law.
The first two issues relate to the reassessments of the statute-barred years.
The third issue relates to the assessment of gross negligence penalties.

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Appeal Issues

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USR292600b83e2a

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"At the hearing of this appeal, Mr. Deyab submitted that the critical point in his appeal is the failure of the Tax Court Judge to take into account all the evidence that was before him. This particular point will be considered in relation to the three issues identified by Mr. Deyab in his memorandum of fact and law.\n\nThe first two issues will be addressed in relation to the reassessments of the statute-barred years and the third issue will be addressed in relation to the assessment of the gross negligence penalties."

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