If the tax commissioner is of the opinion that any taxpayer has failed to include in a return as filed, or to provide during the course of an audit, information necessary to determine a North Dakota tax liability, the tax commissioner may require from the taxpayer an amended return or supplementary information as is necessary to properly and accurately determine a taxpayer’s North Dakota tax liability, in the form prescribed by the tax commissioner. If the taxpayer fails to file the amended return or to furnish the supplementary information, the tax commissioner, after thirty days’ notice, may determine the North Dakota tax liability from the best information available and assess any tax due, including interest and penalty. The taxpayer may protest the determination under the protest procedure provided for the type of tax assessed.