Questione giuridica chiave
Whether the late challenge to the final tax assessments could be treated as a valid remedy despite the lapse of the ordinary deadline.
Decisione estratta
The authority could not enter on the filing as an ordinary objection because the time limit had expired and no reinstatement grounds were shown.
Motivazione estratta
The original assessments had entered into force. The taxpayer's letter was, however, to be assessed by substance rather than label, which opened the way to examine revision.