"Reason to Believe" Standard in Tax Assessments Requires Concrete Basis, Not Mere Suspicion, for Reopening Cases.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment - The words of the statute are "reason to believe" and not "reason to suspect". There can be no manner of doubt that the words" reason to believe" suggest that the belief must be that of an honest and reasonable person based upon reasonable grounds - AT....