When the Commissioner is of the opinion that a taxpayer has failed to file any return required by this chapter, or to include in any return so filed, either intentionally or through error, information by which the taxpayer's tax liability may correctly be determined, the Commissioner may, by written notice to the taxpayer, require that the taxpayer file that return, or an additional supplementary return containing such information, verified as provided in section 5867 of this title, in such form as the Commissioner shall prescribe. The filing of that return shall not relieve the taxpayer from any of the penalties to which he or she may be liable under this chapter.
32 V.S.A. § 5863