26 June 2024

Tax: Meates v. Inland Revenue

 

Doing nothing was fatal for Mark Joseph William Meates, liable for $3.2 million in unpaid tax after failing to dispute this tax assessment within the required four month time frame.

Mr Meates failed to file tax returns for a five year period ending 2018.  Inland Revenue made a default assessment in 2020, assessing Mr Meates as liable for $3.2 million tax.  

The High Court was told it was two years after this default assessment that Mr Meates belatedly filed tax returns for the earlier five year period.  Inland Revenue refused to make any reassessment, suing Mr Meates to recover the claimed $3.2 million.

Challenges to tax assessments must be made promptly.  Tax Administration Act deems any assessment to be correct unless the taxpayer raises objections within four months.

Mr Meates argued that the disputed assessment remained ‘open;’ his tax file was still with Inland Revenue’s legal section.  There had never been any completed assessment at all, he said.

This was dismissed by Justice Preston as an attempt to challenge Inland Revenue’s earlier tax assessment, outside the statutory four month period.

Mr Meates was out of time.  He had no defence to Inland Revenue’s demand for $3.2 million, she ruled.

Meates v. Inland Revenue – High Court (26.06.24)

24.163