Determination of tax: procedural safeguards require notice based limits, hearing rights and time exclusions affecting reassessment and recovery. The statute prescribes procedural safeguards for tax determination: stays by courts exclude time from reassessment limitation periods; appellate findings that fraud was not established require determination under ordinary notice provisions; hearings must be granted on written request or where adverse decisions are contemplated, with limited adjournments and mandated reasons; orders must state relevant facts and basis; demands cannot exceed notice grounds; appellate modification adjusts interest and penalty; interest is payable regardless of explicit mention; unpaid self assessed tax is recoverable under recovery provisions; and penalty for an act under reassessment bars another penalty for the same act.
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Provisions expressly mentioned in the judgment/order text.
Determination of tax: procedural safeguards require notice based limits, hearing rights and time exclusions affecting reassessment and recovery.
The statute prescribes procedural safeguards for tax determination: stays by courts exclude time from reassessment limitation periods; appellate findings that fraud was not established require determination under ordinary notice provisions; hearings must be granted on written request or where adverse decisions are contemplated, with limited adjournments and mandated reasons; orders must state relevant facts and basis; demands cannot exceed notice grounds; appellate modification adjusts interest and penalty; interest is payable regardless of explicit mention; unpaid self assessed tax is recoverable under recovery provisions; and penalty for an act under reassessment bars another penalty for the same act.
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