Questão jurídica principal
Whether revision of the direct federal tax assessment was admissible and timely under Art. 147-148 LIFD
Decisão extraída
Revision was unavailable because the cited judgment was known already at notification of the assessment, no new relevant fact was shown, and the request was in any event filed out of time.
Fundamentação extraída
A fact known to the taxpayer at the time of the assessment cannot be invoked later as a new fact; any omission should have been challenged in the ordinary proceedings, and the 90-day revision deadline had expired.