30 V.S.A. § 25

When the Department of Public Service discovers from the examination of the return or otherwise that the revenue of any company, or any portion of it, has not been assessed, it may at any time within two years after the time when the return was due, assess the same and give notice to the company of the assessment, and within 30 days the company shall have an opportunity to confer with the Department as to the proposed assessment. The limitation of two years to the assessment of the tax or additional tax shall not apply to the assessment of additional taxes upon fraudulent returns. After the expiration of 30 days following the notification, the Department shall reassess the revenue of the company or any portion of it that it finds has not been assessed and shall give notice to the company so reassessed, of the amount of the tax and interest and penalties, if any, and the amount shall be due and payable within 10 days following the date of notice. No additional tax amounting to less than $1.00 shall be assessed.