Questão jurídica principal
Whether the federal appeal was admissible beyond the challenge to the 1995/1996 attempted evasion fine.
Decisão extraída
The appeal was admissible only insofar as it challenged the prescription ruling on the direct federal tax fine for 1995/1996; it was inadmissible for the remainder.
Fundamentação extraída
The federal administration's arguments addressed only that fine, so the conclusions had to be read as limited accordingly.