Mr Rogers lodged his returns of income in the Sydney office of the ATO. The returns of income for the past four years indicate a taxable income below the tax-free threshold. An ATO auditor determined after an extensive investigation that Mr Rogers failed to disclose $400,000 income for the past three years. Mr Rogers was not cooperative throughout the investigation and threatened to leave the country with a suitcase of gold nuggets purchased from the sale of the property. The Commissioner intends to use powers available to him to:

1. raise and serve an assessment making tax payable immediately; and

2. collect the tax debt outstanding.

Required :

What powers would or could the Commissioner use with respect to tax administration law?

(15 marks)