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Adjudicatory treatment of tax liability for parking services must account for material documentary evidence and permit post decisional remedy: where an order rejected a claim that the petitioner acted for a municipal corporation because no Agreement was on file, the court granted liberty to tender supporting documents and required the proper officer to grant a post decisional hearing and decide thereafter; the impugned order was temporar ily held in abeyance and related garnishee proceedings stayed subject to strict filing and decision timetables, and the authority may record supplementary reasons if unconvinced.
Adjudicatory treatment of tax liability for parking services must account for material documentary evidence and permit post decisional remedy: where an order rejected a claim that the petitioner acted for a municipal corporation because no Agreement was on file, the court granted liberty to tender supporting documents and required the proper officer to grant a post decisional hearing and decide thereafter; the impugned order was temporar ily held in abeyance and related garnishee proceedings stayed subject to strict filing and decision timetables, and the authority may record supplementary reasons if unconvinced.
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