Ryan recently disposed Bitcoin but initially did not report this. After an ATO investigation, the ATO issued an Amended Notice of Amendment which reported that he would be liable to pay tax liability totalling $100,000 and this was due 1 January 2021. As Ryan did not have access to additional funds in the short term, Ryan was only able to pay the ATO debt 1 January 2022.

Question

Advise Ryan whether he can challenge the new liability imposed.

Assuming Ryan cannot challenge the new liability imposed, advise what administrative penalty and interest charges Ryan will be subject to and what information need to be provided to request a penalty and interest charge reversal.