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14 Austl. Tax F. 3 (1997)

handle is hein.journals/austraxrum14 and id is 1 raw text is: The Taxation Appeals System: An Administrative Law Perspective Wayne Gumley* This paper considers the tax appeals system by reference to the significant developments in administrative law over the last 20 years. It is concluded that taxpayers are currently provided with a relatively cheap but largely ineffective internal review mecha- nism. There are a number offactors which appear to seriously undermine the potential for effective internal review. These in- clude failure to modify internal review rules after the change to self assessment, the absence of any obligation for the Commis- sioner to provide detailed reasons for an assessment or objection decision, and the general adherence to internal policies by review * Department of Business Law and Taxation, Faculty of Business and Economics, Monash University, Caulfield Campus. The author would like to thank Richard Fayle of the University ofWestern Australia, Susan Weston of the Australian Taxation Office and Phillip Burgess of the University of New South Wales for their helpful comments on this paper.