Questão jurídica principal
Whether the IFD 1997 reassessment was time-barred
Decisão extraída
No; the 15-year extinction period runs from the end of the fiscal period, so the 1997-1998 IFD period was not prescribed.
Fundamentação extraída
The court held that Art. 152(3) LIFD refers to the fiscal period, not the single tax year, and therefore the deadline expired only on 31 December 2013.