Generally, no reassessment or omitted assessment shall be made pursuant to 54:29A-25 after the expiration of more than four years from the filing deadline of a return, except as otherwise provided in 54:49-6(b). In the case of a false or fraudulent return with intent to evade tax, or failure to file a return, the tax may be assessed at any time.
N.J. Admin. Code § 18:23-6.4