Questione giuridica chiave
Whether the objection against the estimated tax assessment met the formal requirements, including filing the tax return and substantiating obvious incorrectness.
Decisione estratta
No. Because the taxpayer did not submit the tax return during the objection period and gave no excusing reasons, the objection failed to satisfy the statutory formal requirements; non-entry was justified.
Motivazione estratta
For estimated assessments, the taxpayer may challenge only obvious incorrectness and must substantiate the objection and name evidence. Where the assessment resulted from failure to comply with cooperation duties, the omitted cooperation, especially filing the tax return, must first be performed; otherwise non-entry follows.