(a) When any person fails to file any form, statement, report or return required to be filed with the commissioner, after being given written notice of the failure to file, the commissioner is authorized to determine the tax liability of the person from whatever source of information may be available to the commissioner or the commissioner's delegates.
(b) An assessment made by the commissioner pursuant to this authority shall be binding as if made upon the sworn statement, report or return of the person liable for the payment of the tax; and any person against whom the assessment is lawfully made shall thereafter be estopped to dispute the accuracy of the assessment, except upon filing a true and accurate return, together with supporting evidence that the commissioner may require, indicating precisely the amount of the alleged inaccuracy.
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