This presentation covers:
- make amended assessments outside the base statutory amendment period:
- default assessments and asset betterment analysis
- basis has to be the Commissioner's opinion that there has been "fraud or evasion":
- what does that mean and when does it have to be formed?
- is the challenge more importantly, either:
- the default assessment is flawed; or
- there should not have been the opinion that there was fraud or evasion?