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Estimation of tax due for any period.
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23.—(1) Where the Revenue Commissioners have reason to believe that the total amount of tax payable by an accountable person, in relation to any period consisting of one taxable period or of two or more consecutive taxable periods, was greater than the total amount of tax (if any) paid by him in relation to that period, then, without prejudice to any other action which may be taken, they may, in accordance with regulations but subject to section 30, make an estimate in one sum of the total amount of tax which in their opinion should have been paid in respect of the taxable period or periods comprised in such period and may serve a notice on the person specifying—
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(a) the total amount of tax so estimated,
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(b) the total amount of tax (if any) paid by the person in relation to the said period, and
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(c) the balance of tax remaining unpaid.
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(2) Where notice is served on an accountable person under subsection (1), the following provisions shall apply:
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(a) the person may, if he claims that the total amount of tax or the balance of tax remaining unpaid is excessive, on giving notice in writing to the Revenue Commissioners within the period of twenty-one days from the date of the service of the notice, appeal to the Appeal Commissioners,
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(b) on the expiration of the said period, if no notice of appeal is received or, if notice of appeal is received, on determination of the appeal by agreement or otherwise, the balance of tax remaining unpaid as specified in the notice or the amended balance of tax as determined in relation to the appeal shall become due and payable as if the tax were tax which the person was liable to pay for the taxable period during which the period of fourteen days from the date of the service of the notice under subsection (1) expired or the appeal was determined by agreement or otherwise, whichever taxable period is the later.
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