Australia, June 24 -- New South Wales Land and Environment Court issued text of the following judgement on May 23:

1. The applicants, Meng Guo and Pu Chen ("Applicants"), challenge an assessment of surcharge land tax made by the Chief Commissioner of State Revenue, the respondent in this matter ("Respondent").

2. The Respondent assessed the surcharge land tax on one of the Applicants, Pu Chen on the basis that she was a "foreign person" for the purposes of the Land Tax Act 1956 ("LTA"). He assessed land tax on the entire value of the relevant land.

3. The Applicants consider that the assessment of surcharge land tax is excessive. This is because, in the Applicants' submission, the land in question was owned beneficially as to 80% by Meng...