Fitzpatrick and Secretary, Department of Families, Housing, Community Services and Indigenous Affairs
[2012] AATA 117
•27 February 2012
Administrative Appeals Tribunal
DECISION AND REASONS FOR DECISION [2012] AATA 117
ADMINISTRATIVE APPEALS TRIBUNAL )
) No 2011/2224
GENERAL ADMINISTRATIVE DIVISION )
Re Brian Fitzpatrick Applicant
And
Secretary, Department of Families, Housing, Community Services and Indigenous Affairs
Respondent
DECISION
Tribunal Senior Member A K Britton and Mr T Jenkins, Member Date27 February 2012
PlaceSydney
Decision The decision under review is affirmed. ........................[sgd]......................
Senior Member A K Britton
CATCHWORDS
SOCIAL SECURITY – benefits – age pension – assets test – applicant had share in real property – valuation of real property – applicant refused on-site inspection – net market value of property – comparable sales – best use of property – decision under review affirmed.
LEGISLATION
Social Security Act 1991 (Cth) – ss 11, 55, 1064
CASE LAW
Drake v Minister for Immigration and Ethnic Affairs (1979) 2 ALD 60
Kirkovski and Secretary, Department of Family and Community Services [2004] FCA 790
Re Woodhouse and Department of Social Security [1987] AATA 73
Re Torv and Secretary, Department of Social Security [1992] AATA 185
Re Secretary, Department of Social Security and Langton (1993) 31 ALD 579; [1993] AATA 315
Re Kennaugh and Secretary, Department of Families, Housing, Community Services and Indigenous Affairs [2011] AATA 346
REASONS FOR DECISION
27 February 2012 Senior Member A K Britton Mr T Jenkins, Member 1. Mr Brian Fitzpatrick seeks review of the decision made by a Centrelink Authorised Review Officer and affirmed by the Social Security Appeals Tribunal (SSAT), valuing the property “Sundale”, in which he has a 50 per cent share, at $1.1 million. Mr Fitzpatrick contends that the proper value of the property is around $850,000.
2. Sundale is not Mr Fitzpatrick’s place of primary residence. Therefore his share of the property constitutes an asset of his, and its value is relevant to the calculation of his rate of age pension (ss 11 and 1064 of the Social Security Act 1991 (Cth) (the Act)). The sole issue to be decided is the proper value of Mr Fitzpatrick’s share of Sundale as at November 2010.
Legislation
3. The rate of age pension is calculated by using the “Pension Rate Calculator A” at the end of s 1064 of the Act (s 55 of the Act). This involves a 12-step process (s 1064-A1). Step 9 of that process involves applying the “assets test” (s 1064-G1). The first step of that test involves “work[ing] out the value of the person's assets” (s 1034-G1).
4. The Act provides no guidance on how the value of a person’s assets is to be worked out. The Guide to Social Security Law (the Guide) is produced by the Department to assist with decision making (see “Guide to Social Policy Law: Purpose”). The Tribunal is not bound to apply the policy expressed in the Guide, but may do so and, indeed, will usually do so unless there are cogent reasons in a particular case for not doing so (Drake v Minister for Immigration and Ethnic Affairs (1979) 2 ALD 60). The Guide provides (at 4.6.6.10) general guidance about how to value assets:
Valuing assets
Assets are generally assessed at their net market value. The net market value is the amount you would expect to receive if you sold the asset on the open market, less any valid debts or encumbrances.
If the asset is owned with another person, the asset value for a customer is determined using their proportion of their interest in the asset.
Example: A customer has a 40% interest in an asset with a market value of $100. The asset value for the customer is $40 ($100 x 40%).
For some assets a valuation is required. For ALL other assets, the customer's estimate is accepted as reasonable UNLESS it appears that the value has been understated AND the value is likely to affect the customer's payment.
Customer estimates
A customer's valuation of an asset should be accepted IF:
it appears reasonable, AND
it is unlikely that payment would be affected even if the actual value was significantly higher.
A customer is NOT expected to obtain professional valuations for any asset. If a customer does however provide a written valuation, this CAN be used to determine market value IF the valuation:
was done by a professionally qualified valuer, AND
conforms with AVO standards.
If there is doubt about the correctness of the valuation, it is treated in the same way as a customer's estimate. Similarly, a valuation opinion provided by someone other than a professionally qualified valuer is treated in the same way as a customer's estimate.
Background to reviewable decision
5. In January 2008 the Australian Valuation Office (AVO) valued Sundale at $1m on the basis of a “roadside inspection” (an external inspection conducted from outside the property). A valuation undertaken 18 months later found that the value of the property had increased to $1.15m and, as a result the rate of pension paid to Mr Fitzpatrick was reduced. Reviewed at the request of Mr Fitzpatrick, the AVO subsequently reduced its valuation to $1.1m. Mr Fitzpatrick unsuccessfully challenged that valuation in the SSAT. The decision to value Sundale at $1.1m, affirmed by the SSAT, is now the subject of Mr Fitzpatrick’s application for review to the AAT.
AVO Valuation
6. In August 2011, Centrelink requested that the AVO prepare a valuation report in respect of Sundale as at November 2010. A copy of that report, prepared by Ms Julie Connell, a certified valuer employed by the AVO, was tendered in these proceedings.
7. Prior to preparing that report, Ms Connell had valued Sundale on three occasions. In January 2008, she valued the property at $1m; in October 2010 at $1.15m, and, in November 2010, at $1.1m. The tendered report is the only report prepared by Ms Connell in respect of Sundale. On her account, it is the practice of the AVO when providing valuations at the behest of Centrelink to prepare written reports only on request.
8. Ms Connell stated in her report that her valuation was based on, among other things, roadside inspections of the property performed in November 2010 and September 2011. For reasons to which we shall return, she has never entered the property.
9. Ms Connell wrote that the property was zoned “Rural Mixed Agriculture under the Hawkesbury Local Environmental Plan 1988 [sic]”. She noted that the property was based in North Richmond and situated on a “dual carriageway bitumen sealed road” that experienced moderate traffic flow. She described North Richmond as a “desirable location” given its close proximity to shops, schools and the township of Richmond itself.
10. In her report Ms Connell described the property as a “slightly irregular shaped Rural Residential acreage allotment that comprises approximately 10-11 hectares of cleared undulating land, the remainder being timbered”. Under the heading “Environmental Issues” she wrote that the Hawkesbury City Council (the Council) had advised her that the property is subject to “Threatened Species” being “Shale Sandstone Transition Forest”. Ms Connell wrote that the Council was unable to confirm the extent, if any, of threatened species on the property and therefore for the purpose of the valuation she had made the assumption that about a third of the property, being most of the seven to eight hectares of heavily wooded area, could be affected.
11. Ms Connell described the house situated on the property as a “C1960’s single level brick wall and tile gable roof with single garage situated under the main roofline … presumed to comprise three bedrooms, one bathroom and basic living areas … presumed to be of original condition internally and overall considered to be [of] fair condition externally”. She described the machinery shed also situated on the property as a “Medium Clearance Iron/Cliplock Constructed Machinery Shed … approximately 25 years … old and in fair condition”.
12. In Ms Connell’s opinion, the “highest and best use” of the property was its existing use as a “rural residential acreage property”, noting that its current zoning prohibited sub-division.
Inspection of the property
13. An issue that has assumed some significance in these proceedings is what was said during a telephone conversation between Mr Fitzpatrick and Ms Connell on 13 November 2010. Each gave divergent accounts of that conversation. Each criticised the other for being argumentative and abusive.
14. Mr Fitzpatrick claimed that in the course of that conversation, Ms Connell offered to reduce the valuation to $1m on the basis of the “restrictive nature of the tree preservation order”. He claimed that when he replied that, while a move in the “right direction”, it failed to take account of other adverse factors, such as aircraft noise, Ms Connell ridiculed him and stated that any reduction below $1m would necessitate an on-site inspection and could result in an increase in the valuation. Mr Fitzpatrick perceived this to constitute a threat. In his opinion this reveals that Ms Connell was incapable of providing an impartial assessment.
15. Ms Connell denied “offering” to reduce her estimate to $1m. She claimed that under the AVO’s Code of Conduct she is prohibited from discussing figures with owners prior to the completion of a valuation. On her account the only reason she contacted Mr Fitzpatrick was to arrange a time to inspect the property, a request he refused. She claims that a colleague who contacted Mr Fitzpatrick after that conversation to arrange a time to inspect the property, was also refused access.
16. While there is considerable disagreement about what was said during the course of the disputed conversation, it is agreed that since 13 November 2010, Mr Fitzpatrick refused to permit Ms Connell or any other officer of the AVO to conduct an on-site inspection of Sundale, unless guaranteed that any revised estimate would not result in an increased valuation.
Mr Fitzpatrick’s analysis of the AVO report
17. Mr Fitzpatrick contends that the report prepared by Ms Connell is deeply flawed, marred by error and contaminated by bias. He contends, among other things, that Ms Connell:
·failed to have proper regard to the effect of aircraft noise;
·failed to have proper regard to the impact of “threatened species”;
·wrongly assumed that Currency Creek ran over the property;
·incorrectly described the road on which Sundale is situated as a “dual carriageway”;
·incorrectly categorised Sundale as “rural residential acreage”;
·wrongly assumed that the house, machinery shed and fencing were in “fair” condition;
·focussed on Sundale’s positive features and failed to give sufficient weight to negative features such as lack of public transport; traffic congestion, town water and extremes of temperatures;
·unlawfully relied on a valuation prepared by the NSW Valuer General; and
·compared Sundale with properties that were not comparable.
Aircraft noise
18. Mr Fitzpatrick contends that Sundale is severely affected by aircraft noise — a factor ignored by Ms Connell. In support, he points to diagrams prepared by aviation community advocate Mr A G Williams, which show the flight path used by aircraft departing from Sydney airport’s north-west runway, narrowing over Richmond. He contends that having spent a great deal of time over an extended period at Sundale, he is well placed to comment on the impact of aircraft noise.
19. In oral evidence, Ms Connell claimed that she had also spent a great deal of time in the Richmond area as part of her role with the AVO and in the management of private property interests. She did not agree with Mr Fitzpatrick’s contention that Sundale was “severely affected” by aircraft noise or that any aircraft noise was at a level that would impact on its value. She claimed that any aircraft noise would equally affect “comparable sales” (see below at paragraph 39-44) in the surrounding area.
Threatened species
20. According to Mr Fitzpatrick, Ms Connell failed to give proper regard to the impact of “threatened species” on the value of Sundale. He contends there was no basis for her assumption that “Shale Sandstone Transition Forest” was the only “threatened species” on the property. He stated that until an environmental assessment is conducted, the possibility that the property might be affected by other threatened species could not be excluded.
21. In her report Ms Connell wrote she had been advised by a Council officer that the property was “subject to threatened species” but the “exact extent” was unknown. On the basis of an aerial photograph, revealing about a third of the property to be heavily wooded, Ms Connell assumed that this area was affected by a “Shale Sandstone Transition Forest”. She concluded that that area might be subject to development restrictions which could diminish the value of the property. In oral evidence, Ms Connell conceded that the Council was her sole source of information about this issue and she could not exclude the possibility that other threatened species might be present on the property. She explained that an environmental assessment of the type Mr Fitzpatrick contends is necessary had not been conducted and was not within the AVO’s area of expertise. On her account, that assessment would be costly and generally would only be undertaken if development was planned.
22. Ms Connell disputed that she failed to have proper regard to the possible impact of threatened species. In oral evidence she stated this factor had caused her to arrive at a per hectare land value rate of $55,000, not $80,000 to $85,000, the rate she asserted would apply were it not for the assumption she had adopted that about a third of the property could be subject to restrictions on development.
Currency Creek
23. Mr Fitzpatrick contends that Ms Connell incorrectly assumed that Sundale enjoyed water flow from Currency Creek. On his account, there is no creek on the property; at best, after periods of “excessive rain”, small gullies of water form in low lying areas.
24. Ms Connell wrote that “topographic maps indicate a creek line known as “Currency Creek” situated to the rear of the property. In oral evidence, she stated that these types of creek lines are typical for the area. She stated that as she had not entered the property, she could not say whether the creek was perennial or non-perennial. She disagreed that the reference to the creek line in the report indicated that she believed it to be a feature that added to property’s value. She claimed that in an area such as the Hawkesbury, which enjoyed high rainfall, the existence of a creek line did not add to a property’s value and that she had not assumed that it would. She stated that based on aerial photographs revealing dams that were not in the vicinity of the creek line she had assumed that the property’s water came from these dams.
Dual carriageway
25. Mr Fitzpatrick contends that Ms Connell mistakenly assumed that Kurmond Road, which Sundale fronts, is a “dual carriageway” and inflated her valuation as a result. He describes Kurmond Road as “a bitumen-sealed country road carrying two-way traffic, 5.6 metres in width”. He contends that the term “dual carriageway” can only be employed where traffic flowing in opposite directions is separated by a gap. In support, he relies on the Oxford English Dictionary which defines “dual carriageway” to mean:
A road with separate carriageways, divided by a central strip, for up and down vehicular traffic.
26. On questioning, Ms Connell agreed with Mr Fitzpatrick’s description of Kurmond Road. She claimed to be unaware that the term “dual carriageway” had the limited meaning suggested by him, but stated that she had taken account of the road as it actually was, and as described by Mr Fitzpatrick.
Value of improvements to the property
27. Mr Fitzpatrick submitted that Ms Connell’s estimate of $100,000 for the total value of the house and the machinery shed was grossly inflated.
28. He testified that the house had been purchased and transported to Sundale in the mid-1970’s for $10,000 (inclusive of transport and building costs). He claims that it is in poor condition and among other things, needs a new roof, gables, fascias and guttering, and showing that the rear of the house was of weatherboard construction, not brick. He tendered recent photograph of the house in support. He claims that since advising Centrelink in 2007 that the property was in “fair condition” it has deteriorated significantly, particularly its woodwork.
29. When questioned about her description of the house as being in “fair condition” Ms Connell stated that she had relied on the information provided by Mr Fitzpatrick to Centrelink in 2007. When taken to the photographs of the house, referred to above, Ms Connell stated that they were consistent with her understanding that it was in original and fair condition consistent with its age. She explained that for this reason she had given the house a “nominal value” of about $75,000.
30. On questioning, Ms Connell did not agree with the proposition that her estimate of the value of the machinery shed, $25,000 was inflated. She claimed that the shed, which could be seen from the roadside, appeared to be in reasonable condition commensurate with its age.
Categorisation of the property as “rural residential acreage”
31. Mr Fitzpatrick asserted that the proper categorisation of Sundale is “modest commercial farming property zoned for agricultural use” not, as Ms Connell believes, “rural residential acreage”. Ms Connell stated that unirrigated properties of a similar size to Sundale in the Richmond area are predominantly used for mixed rural and residential purposes — by homeowners who run a few horses or head of cattle. According to Ms Connell, an unirrigated property of Sundale’s size in the Richmond area would not be considered a viable pastoral property for valuation purposes.
Condition of fencing
32. Mr Fitzpatrick contends that Sundale’s fencing is in poor condition and not, as described by Ms Connell, “capable of stock proofing”. He contends that cattle routinely escape from the property in poor weather. He claims it would cost about $50,000 to bring the fencing up to “fair condition”.
33. Ms Connell did not agree. On her account, the fencing visible from the roadside inspection appeared to be in “fair” condition.
Valuer General
34. Mr Fitzpatrick asserted that Ms Connell erred by taking into account valuations prepared by the NSW Valuer General, an independent statutory officer who oversees the valuation of properties in NSW. Valuations prepared by the Valuer General are used for rating and taxing purposes and only address the land component of the property.
35. Mr Fitzpatrick contends that Ms Connell unlawfully relied on information obtained from the Valuer General. In support he points to attachments to her report entitled “Land value search”, which state:
The land value recorded on this land value search has been determined under the Valuation of Land Act 1916 for rating and taxing purposes. Land values have regard to the requirements of rating and taxing legislation and should not be used for any other purpose without the specific agreement of the Valuer-General. [emphasis added]
36. In addition, he asserts that Ms Connell incorrectly asserted in her report that “the statutory value” of the property (the valuation provided by the Valuer General) was $1.17m (in 2009) and $1.37 (in 2010). He points out that in November 2009 he was notified by the Valuer General that his objection to the 1 July 2008 valuation had been upheld and a revised valuation of $950,000 issued (Exhibit A5).
37. Ms Connell stated that she obtained the reports in question from a publicly accessible database maintained by Land and Property Information (LPI) (a division of the Department of Finance and Services which manages the valuation process on behalf of the Valuer General). She asserted that the AVO’s practice when preparing reports is to refer to, but not rely on, the statutory value of a property. She stated that it was her understanding that this use was permitted by the LPI.
38. Ms Connell claims that she had not mentioned the revised valuation in her report because she was unaware of it and there is no reference to it on the LPI’s publicly accessible database. She stated that notwithstanding the evidence of a revised valuation she remained confident of her opinion. She argued that that the Valuer General’s revised valuation of $950,000 (as at July 2008) was broadly in line with her valuation of $1m (as at November 2010). On her account, property values in the North Richmond area had increased by about 5 per cent per annum between 2008 and 2010. Mr Fitzpatrick disagreed.
Comparable properties
39. For the purpose of her report, Ms Connell looked at six properties in the Richmond area. The report included details of each property and a commentary prepared by Ms Connell as summarised in the table below:
SALE PRICE
ZONING
COMPARISON
RATE PER HECTARE
1 $1.7m Mixed Agriculture Superior to Sundale offering a much higher standard of accommodation. $98,814 2 $1.025m Mixed Agriculture Inferior to Sundale offering an inferior level of accommodation and inferior land quality and size. $84,167 3 $1.275m Mixed Agriculture Superior to Sundale offering a higher level of accommodation. $79,086 4 $1.2m Mixed Agriculture Superior to Sundale offering a higher standard of accommodation and general improvements $71,915 5 $1.28m Environmental Protection – Agriculture Protection – Clause 11(2) subdivision hatching on LEP Map – The property has no subdivision potential and offers similar permitted uses to the subject. Superior quality land to Sundale with good outlook. $86,253 6 $680,000 Rural Living Inferior improvements, land quality and location to Sundale. $42,001 40. Noting that these properties ranged in price from $680,000 to $1.7m, or $42,000 to $98,000 per hectare, Ms Connell concluded that the rate of $55,000 per hectare she had arrived at for the land component of Sundale was appropriate “taking into account that approximately 7-8 hectares of the site is affected by restrictions on development
41. Mr Fitzpatrick contends that the properties selected by Ms Connell provide a poor basis of comparison because first, all were sold before Sundale’s purported valuation on 3 November 2010, that is, throughout the period March 2010 to September 2010; second, a number were demonstrably superior to Sundale in terms of both improvements and land; third, Ms Connell incorrectly described Property 1 as being zoned “mixed agriculture” when it was in fact “rural living”; fourth, in contrast to Sundale, a number of the selected properties were “ripe for redevelopment” given their proximity to a town or village. In addition, he asserted that Ms Connell understated or omitted some positive features of the selected properties such as Property 1’s “substantial and uninterrupted views” of the Blue Mountains and close proximity to the village of Kurmond.
42. Ms Connell did not agree with the proposition that the selected properties offered a poor basis for comparison. While she conceded that none were identical to Sundale, she pointed out that first, all were within a five kilometre radius of Sundale; second, there had been no significant movement in the North Richmond market from the time the selected properties were sold until when Sundale was valued; third, like Sundale, none could be subdivided; fourth, the zoning of each was broadly comparable to that of Sundale (she conceded that Mr Fitzpatrick was correct and Property 1 was zoned “rural residential” not “mixed agriculture”). She agreed that a number of properties were superior to Sundale in terms of land and/or improvements but pointed out that this had been factored in to her analysis and acknowledged in her report.
43. Mr Fitzpatrick selected and commented on three properties that he contended provide a more appropriate basis of comparison with Sundale, set out in the table below:
Other Kurmond Road Property
Marked as “K” in Exhibit A1House is quite large – possibly 20 to 30 rooms
90% of land cleared (an estimate from observation)
Extensive views of blue mountains.
34 hectares of land, from inquiries with Council.
Capable of subdivision under LEP into three allotments.
Road access.
Irrigation water access.
Bilpin Property Asking price $845,000 reduced from $ 895,000
Whole property usable.
34 “nearly all arable acres”.
Seems to be in far better condition than subject property.
Highly sought after location because above smog line.
Sackville Property Asking price $1,100,000
Advertised as four bedroom home with ducted air conditioning, amazing rural views, magnificent landscaped gardens, sparkling in ground pool and al fresco area, four stables, tack and feed room and fenced paddocks, large workshop, machinery shed, 25 river front acres with 160 metres of river frontage.
44. Ms Connell did not agree that the Bilpin property provided an appropriate basis for comparison. She pointed out that Bilpin was 25 kilometres from North Richmond and, in her opinion was a “very different market”.
Findings and conclusions
45. We must decide the proper value of Sundale at November 2010. The Act does not specify how real property should be valued. The Federal Court in Kirkovski and Secretary, Department of Family and Community Services [2004] FCA 790 endorsed the approach that had been, and continues to be, employed by the Administrative Appeals Tribunal when undertaking that task — considering the net market value of the subject property based on comparable sales and the “best use” to which it could be put (see Re Woodhouse and Department of Social Security [1987] AATA 73, Re Torv and Secretary, Department of Social Security [1992] AATA 185, Re Secretary, Department of Social Security and Langton (1993) 31 ALD 579; Re Kennaugh and Secretary, Department of Families, Housing, Community Services and Indigenous Affairs [2011] AATA 346). That approach is reflected in the Guide which states that an asset is generally assessed at its “net market value” — the amount a seller would expect to receive if the property was sold on the open market, less any valid debts or encumbrances.
46. As noted, Ms Connell did not conduct an on-site inspection. As a consequence, some of the factual assumptions she made, such as the state of improvements to the property, were based on imperfect knowledge. In an effort to cure this problem and address Mr Fitzpatrick’s concerns, we proposed to the parties that the AVO be requested to provide a fresh assessment prepared by someone other than Ms Connell after an on-site inspection had been conducted. Mr Fitzpatrick rejected this proposal. Given this impasse we had no option but to determine the value of the property on the material before us.
47. The starting point for Mr Fitzpatrick’s contention that the proper value of Sundale is $850,000 is the Valuer General’s revised valuation of $950,000. To this figure he added an amount of $20,000 for the house and shed and deducted $120,000 for “the damage and expense from the threatened species legislation”. On the information before us, we are unable to discern the assumptions that underpinned the revised valuation and, importantly whether, as Mr Fitzpatrick contends, the Valuer General had ignored the threatened species issue. Nor has Mr Fitzpatrick explained the basis for his opinion that $120,000 would constitute an appropriate reduction, if that were the case.
48. Mr Fitzpatrick disagrees with Ms Connell’s opinion that the value of the property is $1.1m, contending that she is biased and her method of assessment is flawed. Among other things, he believes that Ms Connell overstated Sundale’s positive features and ignored what he considers to be its many negatives.
49. Mr Fitzpatrick has the benefit of first hand and detailed knowledge of both Sundale and its surrounding area. While we accept that his opinion about the impact various features of the property have on its value are genuinely held, he has no expertise in the area of property valuation. Ms Connell on the other hand has both qualifications and experience in this area. Her detailed report sets out the assumptions on which her opinion is based. She has provided a reasoned explanation for her conclusion about the value of the property. Her responses to various propositions put to her in cross-examination were cogent and plausible. As she points out, her opinion is broadly in line with the revised valuation provided by the Valuer General.
50. The Guide does not require a social security recipient to obtain an expert opinion about the value of an assessable asset. Indeed the Guide makes plain that the recipient’s opinion ought generally be accepted if it appears reasonable. The effect of the Guide is that an expert opinion does not automatically prevail.
51. As Mr Fitzpatrick points out, another valuer might hold a different opinion to Ms Connell about the value of Sundale or the factual assumptions on which her opinion rests. It is a matter of common knowledge that experts sometimes differ even where they hold similar qualifications and employ the same methodology. The field of property valuation is no exception. However this does not advance Mr Fitzpatrick’s case. Absent an alternative expert opinion it is a matter of speculation and conjecture as to whether, as Mr Fitzpatrick contends, other experts might share his opinion about the value of the property.
52. It is unfortunate given Mr Fitzpatrick’s misgivings about the reliability of Ms Connell’s opinion that he declined the proposal that a further valuation be undertaken by a different AVO valuer. Given that he did decline this proposal, however, on the material before us we do not consider that it would be appropriate to depart from the existing AVO valuation and we have accordingly decided to affirm the decision under review.
I certify that the 52 preceding paragraphs are a true copy of the reasons for the decision herein of Senior Member A K Britton and Mr T Jenkins, Member.
Signed: .................................[sgd]...............................
Associate to Senior Member A K BrittonDates of Hearing: 21 October 2011, 19 December 2011 and
10 January 2012
Date of Decision 27 February 2012
Applicant: In person
Solicitor for the Respondent: Ms J Maclean, Centrelink Program Litigation and
Review Branch
0
2
1