Key legal question
Whether the administrative tax appeal against the estimated assessment was admissible despite the missing tax return
Extracted holding
The appeal was inadmissible because the taxpayers did not cure the missing return and did not provide the required substantiated challenge to the estimated assessment.
Extracted reasoning
Against an estimated assessment, the taxpayer must show obvious incorrectness in the objection and must do so with a reasoned objection within the time limit. Since the taxpayers still had not filed the tax return, the authority could not verify completeness and correctness of all income declarations.