Questão jurídica principal
Whether a change in jurisprudence can justify revision of a final direct federal tax assessment under Art. 147 LIFD.
Decisão extraída
No. A mere error in applying the law, including a later change in case law, is not a ground for revision; the assessment was not manifestly erroneous at the decisive time.
Fundamentação extraída
Revision under Art. 147 LIFD is limited to newly discovered important facts/evidence or serious procedural defects. The tax office learned of the new precedent only after the decision, and the later publication of the judgment meant no manifest error had to be noticed at the time of the decision.