Questão jurídica principal
Whether the taxpayer could invoke good faith to oppose a corrected tax assessment including unemployment benefits received in 1993.
Decisão extraída
No. Because he knew his 1994 tax return could still be corrected depending on the outcome of the dispute with the unemployment fund, he could not rely on good faith to block the rectification.
Fundamentação extraída
The decisive point was the taxpayer's awareness that the tax return was provisional in light of pending proceedings concerning unemployment insurance benefits. In those circumstances, the later corrective assessment was foreseeable and good faith protection did not apply.