For the past 18 months Cove Legal has been representing two tax payers in their long running battle with the ATO over amended assessments that demanded amounts which the clients argued were considerably in excess of their genuine debts. The case has raised relatively novel issues concerning the use of freezing orders and the summary judgment process in cases where it is argued the tax payers have not had the opportunity to properly challenge the ATO's assessment. An Appeal is currently being run by Cove Legal before the Full Federal Court that includes a constitutional challenge to the imposition of tax debts without a proper right of review.