Key legal question
Whether the estimated direct federal tax assessments for 1989/90 to 1993/94 were shown to be incorrect
Extracted holding
The taxpayer did not prove that the estimation was unfounded or wrong; the assessments remained upheld.
Extracted reasoning
In an estimation tax case, the taxpayer bears the burden of showing that the authority's assessment lacks a reliable basis. His new factual assertions about low staff use and subcontractors were raised too late and were unsupported. The court also noted that destroyed business records did not help him, especially since record-retention duties still applied for part of the relevant period.