Question juridique clé
Whether the objection against an estimated tax assessment met the heightened reasoning and evidence requirements
Solution extraite
No. The objection had to be reasoned and supported by at least a concrete offer of evidence within the objection period; a mere later-filed tax return did not suffice.
Motifs extraits
For objections to estimated assessments, the reasoning and evidence requirements are procedural prerequisites. Without a minimum objection statement, the tax authority must not enter into the objection.