Abstract:
Since the introduction of the self-assessment system in Australia there have
been a number of reviews into the system. An issue that has not been
adequately addressed by these reviews relates to the making of an
assessment, and the status carried by an assessment. This article reviews
the legislative provisions and judicial considerations concerning the making
of an assessment, and examines how these operate in a self-assessment
system. The article suggests that, even in a self-assessment system, the
notice of assessment issued by the Commissioner completes the process of
making an assessment. On this basis, the article briefly outlines some
strategies which may allow the Commissioner to provide the notice of
assessment with the certainty and finality it implies