Adjunct to the presumption of regularity in the performance of official duties is the presumption of correctness of a tax assessment. Well established is the rule in taxation that assessments are prima facie presumed correct and made in goodfaith. An assessment fixes and determines the tax liability of a taxpayer. As soon as it is served, the taxpayer concerned is supposed to be obligated to pay the amount assessed and demanded.

Although the presumption of regularity of assessments is expressed in a language superior and demanding, the power that shields an assessment is not without limits. It actually imposes a great responsibility on the tax authorities to ensure that every assessment wears the badge of credibility and due diligence.

Challenging the merit of presumed regularity