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    <description>An opportunity of personal hearing before an adverse tax determination is satisfied where the proper officer considers the taxpayer&#039;s representation, grants hearings after receiving the response, and the authorised representative confirms that written submissions are final. A further hearing is not required merely because the determination order is issued later. The notes also state that refund of amounts recovered before expiry of the appeal period need not be directed where writ proceedings were not instituted within the statutory appeal period. The taxpayer may pursue the appellate remedy, with time spent in writ proceedings excluded for limitation, while issues other than the hearing question remain open.</description>
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