Any person against whom assessment is made pursuant to section 3016 or 3018 of this title may appear in person or by counsel in the office of the Commissioner within 15 days after the mailing to him or her of notice of the assessment then and there to show cause why the assessment is in error or to present any other facts or testimony that would bear on the amount of the assessment or the manner in which it was made. The hearing may be continued from time to time. If the person or his or her agent does not appear within the 15 days, the assessment shall become final.
23 V.S.A. § 3019