Question juridique clé
Whether the direct federal tax claim for 1993-1994 was time-barred
Solution extraite
No. The limitation periods were interrupted by several procedural acts, and neither the relative nor any applicable absolute limitation period had expired.
Motifs extraits
Under the old direct federal tax regime, the relevant limitation was a relative five-year period interrupted by acts aimed at collection; the 2001 objection decision and earlier correspondence interrupted it. Under the new law, the claim was also not time-barred.