Question juridique clé
Whether the late challenge to the final tax assessments could be treated as a valid remedy despite the lapse of the ordinary deadline.
Solution extraite
The authority could not enter on the filing as an ordinary objection because the time limit had expired and no reinstatement grounds were shown.
Motifs extraits
The original assessments had entered into force. The taxpayer's letter was, however, to be assessed by substance rather than label, which opened the way to examine revision.