10 Oct 2013
FALOON v INLAND REVENUE [2013] NZHC 2643
- Citation
- [2013] NZHC 2643
- Court
- High Court
Because s89M(11) authorises an application for more time to reply only in the context where the Commissioner initiated the dispute and a statutory right of reply to the Commissioner's SOP exists, and because the taxpayer initiated this dispute so no such right of reply exists, the applicant cannot obtain relief under s89M(11) and leave to bring the Originating Application must be refused.