However, accepting such an approach would negate out of hand the possibility of a taxpayer claiming a legal error, and as I have already noted above, there is no basis for this. In the same way, there is no basis for the conclusion that only a taxpayer who was not represented may request to amend the assessment due to a legal error.
It is not superfluous to emphasize that when an argument such as the one raised by the respondent in the appeals in this case is being considered, one should not ignore or forget the fact that according to the law the Real Estate Taxation Administration has the legal possibility of amending an assessment due to a legal error of any kind, including a change in the classification of the transaction (for example, whether it is a qualifying residential apartment, or the purchase of a "right in real estate", etc.), when there is no dispute that the entire rank of officials in the Real Estate Taxation Office is inspectors, Coordinators, field managers, deputy managers and managers of the Real Estate Taxation Office – all are professional, experienced entities with all the professional knowledge as well as the legal knowledge required for examination, auditing and issuing assessments.
Therefore, if such skilled and professional entities in the Real Estate Taxation Office may also make a mistake on the legal level, and the law allows them to amend the assessment due to a legal error, I have not found any reason or legal reason to deny this possibility to the taxpayer, even if he was represented by an attorney at the stage of declaring and submitting the self-assessment.
- Moreover, as I have determined above, there is no room for a distinction between a taxpayer and the Land Taxation Administration with respect to the types of claims that may be made in the framework of a request to amend an assessment. Article 85 The law and the case law that discussed it created equality between the taxpayer and the Real Estate Taxation Administration in all matters related to and relating to the request to amend an assessment, and it was determined that the cause of action in section 85(a)(3) The law means the discovery of a factual or legal error, to the taxpayer or the real estate tax manager.
The Real Estate Tax Administration also sometimes changes its legal interpretation of a particular transaction that is reported to him. Should the Real Estate Taxation Administration be denied the possibility of correcting a legal error in an assessment issued by him?