Question juridique clé
Whether direct federal tax claims for 1987-1992 were absolutely time-barred under transitional rules.
Solution extraite
The tax claims were absolutely prescribed by 31 December 2006 under the transitional application of the LIFD limitation rules to AIFD claims.
Motifs extraits
The AIFD governed the old periods, but the LIFD's absolute limitation periods apply by transitional analogy. Because the assessments became final in April 1996, the ten-year period for collection started at the beginning of 1997 and expired at the end of 2006. Good faith and alleged delay by the taxpayer did not bar reliance on prescription.