Questão jurídica principal
Whether an objection against a discretionary federal tax assessment must be dismissed when the self-assessment was filed only after the objection period and the objection lacked timely supporting evidence.
Decisão extraída
An objection against a discretionary assessment must state reasons and evidence; if evidence is missing, a grace period may be set. Here, the late-filed self-assessment and evidence still showed the assessment to be manifestly incorrect, so the appeal was upheld and the case remitted for a substantive reassessment.
Fundamentação extraída
The court distinguished between a deficient objection lacking any substantiation, which is inadmissible without cure, and an objection that contains a request and reasoning but lacks evidence, which may be cured by a set deadline. Although the self-assessment was submitted long after the objection deadline, the subsequently filed documents sufficiently proved the assessment was manifestly incorrect.