Questione giuridica chiave
Whether the appellate court made a legally relevant erroneous finding of fact about the 2001 deposits.
Decisione estratta
No; the deposits the taxpayer relied on were not included in the reassessment, so there was no indication of an unlawful factual finding.
Motivazione estratta
The challenged amounts were not part of the income additions, making the objection factually unfounded.