Yerushalmi discussed the nature of the proceedings, and the two stages in which the assessment is examined by the Tax Authority: "... The assessment hearing, within the framework of the civil tax assessor, is conducted in two stages. Assessment stage A, which is before a supervisor on behalf of the tax assessor. Then, if there are no agreements, a reasoned objection is submitted, and then, another stage, assessment B. If there are no agreements even at the second assessment stage, an order is submitted by the tax assessor to the district court in the area, followed by an appeal and proceedings in the district court in the area" (Prov. p. 743, s. 2).
(d) In the course of those proceedings that took place before the tax assessor, a number of meetings were held and the defendant's claims regarding his being a foreign resident were examined.
Yerushalmi described the proceedings as follows: "Mr. Nanikashvili was, in fact, a partner in the assessment proceedings... In Stage A and in Stage B, he sat in my office at least once, and afterwards he also appeared to the representatives several times... Full cooperation, there were discussions that lasted for many hours. Appearing with representatives, he laid out his approach to the subject in dispute. Cooperation seems to be found in all the details, in all matters. Although there are no agreements between us, but in any case, we, we have been cooperated, personally, not professionally, there are deficiencies that we believe should be filled anyway and we did not accept them. But, he showed up and was ready..." (Prov. p. 744, paras. 19-32).
There is no dispute that in the framework of those proceedings, the defendant hired the services of Adv. Udi Barzilai, who submitted a written application to the Tax Authority on the same matter (the defendant's testimony, prov. p. 1251, s. 32 - p. 1252, s. 3).
(e) The defendant's arguments that his center of life is abroad and that he should be regarded as a foreign resident did not convince the Tax Authority, and on December 26, 2010, the first assessment was issued for the tax year 2005 (testimony of Yerushalmi - Prov. p. 743, s. 21) and see also the testimony of the defendant who described what happened on the day the assessment was received: "I receive an assessment according to the best judgment of the sum that appears 300 million NIS for one year" (Prov. p. 1252, s. 9).