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    <description>Challenge to notices for reopening assessment turned on whether statutory pre-conditions under the reopening scheme were complied with; the court found the inquiry under the procedural provision was conducted, documents were furnished, the taxpayer had opportunity to respond, and approval by the prescribed higher authority was obtained. The court treated relied-upon statements, documentary records and survey findings as prima facie material justifying issuance of the notice and distinguished authority relied on by the taxpayer on factual grounds, and consequently dismissed the petition and upheld the order and notice.</description>
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      <description>Challenge to notices for reopening assessment turned on whether statutory pre-conditions under the reopening scheme were complied with; the court found the inquiry under the procedural provision was conducted, documents were furnished, the taxpayer had opportunity to respond, and approval by the prescribed higher authority was obtained. The court treated relied-upon statements, documentary records and survey findings as prima facie material justifying issuance of the notice and distinguished authority relied on by the taxpayer on factual grounds, and consequently dismissed the petition and upheld the order and notice.</description>
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