Explain in your own words the tax policy reason behind section 118-195 Income tax Assessment Act 1997

Explain in your own words the tax policy reason behind section 118-195 Income tax Assessment Act 1997 with respect to deceased estates. In so doing discuss why the commissioner has been given the discretion to extend the two year period . Your answer must be supported by reference to legislation case law and tax rulings if any... note: Australian taxation law