Key legal question
Whether the appeal against the discretionary assessment was admissible and whether the assessment could be reviewed for manifest error.
Extracted holding
The court entered into the appeal, but held that a discretionary assessment may only be challenged for manifest incorrectness and that this was not shown.
Extracted reasoning
The bookkeeping contained numerous defects; the later submissions did not restore probative value. Partial evidence is insufficient to overturn a discretionary assessment.