Effective opportunity in reassessment requires disclosure of relied-upon material before the taxpayer submits meaningful objections to proposed liability.

Effective hearing in reassessment requires disclosure of material relied upon so the assessee can provide a meaningful response. Where illness supported by medical material prevented the assessee from using earlier statutory opportunities, relevant information, including monitoring-committee data, should be furnished before objections are considered. The note states that a fresh opportunity to contest the proposed tax liability is required to balance the assessee's right to be heard with Revenue interests.

---

---

Issues: Whether the assessment could be reopened for enabling the assessee to receive the material relied upon and submit objections.

Analysis: Although the statutory procedure and hearing notices had been issued, the assessee had not availed the opportunity because of illness supported by medical material. In view of the need to afford an effective opportunity and to balance the interests of the assessee and Revenue, the relevant information, including the monitoring-committee data, was required to be furnished for a meaningful response.

Conclusion: The assessee was entitled to a fresh opportunity to contest the proposed tax liability after disclosure of the relevant material.

---