It was a smart move by a former government – I believe it was the Burnham government – to amend the Income Tax legislation to make it possible for the Income Tax Commissioner to assess taxpayers with unduly high assessments and prevent their appeals to the Board of Review unless a substantial part of the assessment was paid in advance.
In its Guide to Income Tax Legislation the Inland Revenue Department states:-
“Within fifteen days of the date of the refusal of the Commissioner to amend the assessment, the taxpayer who remains aggrieved may file a Notice of Appeal to the Board of Review