(1) A WRA assessment—
(a) may be made only in the [four] cases specified in subsections [(2), (3)][, (3A) and (3B)], and
(b) may not be made in the circumstances specified in subsection (4).
(2) The first case is where the situation mentioned in section 54 or 55 was brought about carelessly or deliberately by—
(a) the taxpayer,
(b) a person
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