Question juridique clé
Whether the challenge to the 10 February 2003 tax decision could be heard again despite the earlier final judgment.
Solution extraite
The issue could not be revisited because the earlier judgment had entered into force and barred a new assessment.
Motifs extraits
The taxpayer had already been invited in the earlier case to explain the late filing and therefore knew of the decision; any complaint had to be raised against the 13 May 2003 judgment. The prior judgment was final and created res judicata.