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    <title>REVIEW CANNOT BECOME A BACKDOOR APPEAL</title>
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    <description>Review jurisdiction is a narrow corrective remedy and cannot substitute for an appeal or fresh hearing. A reviewable error must be clear and self-evident without extended reasoning or reconsideration of competing interpretations. New material must be genuinely important, previously unavailable despite due diligence, and relevant to the decision. Patent illegality must be a serious and obvious defect going to the root of the matter. The article states that the GST annuity dispute was directed to the statutory appellate forum because it required examination of contractual and factual issues, and that dismissal of review did not finally determine whether the annuity was taxable or exempt.</description>
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      <link>https://www.taxtmi.com/article/detailed?id=16934</link>
      <description>Review jurisdiction is a narrow corrective remedy and cannot substitute for an appeal or fresh hearing. A reviewable error must be clear and self-evident without extended reasoning or reconsideration of competing interpretations. New material must be genuinely important, previously unavailable despite due diligence, and relevant to the decision. Patent illegality must be a serious and obvious defect going to the root of the matter. The article states that the GST annuity dispute was directed to the statutory appellate forum because it required examination of contractual and factual issues, and that dismissal of review did not finally determine whether the annuity was taxable or exempt.</description>
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