Questão jurídica principal
Whether the supplementary appeal against the direct federal tax assessment was timely after personal re-service of the decision
Decisão extraída
The supplementary filing did not reopen the appeal period; only the registered decision served on the representative was appealable.
Fundamentação extraída
Service on the authorized representative triggered the 30-day period. The later personal, unregistered transmission was only a confirmation and expressly could not create a new deadline absent nullity.