NAC360.401. Acceptance of late return filed after deficiency determination is proposed.

The acceptance by the Department of a late filed return may not be construed as a settlement or other resolution of the proposed deficiency determination pursuant to NRS 360.360 so as to permit the taxpayer to raise the issue of res judicata or collateral estoppel during any subsequent examination or audit of the records of the taxpayer. If the late filed return is filed after the 45-day due date, the Department shall not accept the return without verification of the amounts on the return, unless the differences between the proposed deficiency and the subsequent late filed return are de minimis.

     (Added to NAC by Tax Comm’n by R032-03, eff. 10-30-2003)