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Managing tax disputes can be like wrestling with a superhero

It is sometimes said that a superhero like the DC Comics character Superman can be uninteresting because he is, for all practical purposes, indestructible. Critics have said the knowledge that he will most likely win can make Superman's adventures monotonous. A similar accusation could be leveled at the Federal Commissioner of Taxation (the flesh and bone personification of the ATO). To most people, including a hefty majority of small and medium businesses, the Commissioner appear to be immune from defeat. He has extraordinary powers - he can require a taxpayer to produce almost any documents even if he doesn't know whether the taxpayer has done any wrong; his assessments (or amended ass

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