Questão jurídica principal
Whether the revision of the final direct federal tax assessment was admissible under Art. 147 DBG
Decisão extraída
No statutory ground for revision was shown; the appeal arguments could and should have been raised in the ordinary proceedings.
Fundamentação extraída
The appellant relied mainly on general criticism and on the claim that he was not a shareholder and thus had no transposition income. Even if this could be read as invoking overlooked facts, that objection was available already in the original assessment procedure, so Art. 147(2) DBG bars revision.