Questão jurídica principal
Whether the discretionary tax assessment for 2005 was obviously incorrect and therefore could be overturned
Decisão extraída
No. The taxpayer did not substantiate obvious incorrectness; the assessment based on prior-year income remained within the authority's estimation margin.
Fundamentação extraída
A discretionary assessment can only be attacked by showing obvious error comprehensively, including by submitting missing proof and addressing all assessment elements. The taxpayer relied mainly on an unproven later-filed return and unsupported claims of family support; the authority's reliance on prior-year earnings was acceptable.