Questione giuridica chiave
Whether the unreported liquidation surplus justified a back-tax assessment despite the prior final assessment.
Decisione estratta
The surplus was not a known fact imputable to the tax authority; the conditions for excluding back tax were not met, so back tax had to be levied.
Motivazione estratta
The taxpayer had not disclosed the liquidation surplus at all, and the authority had no duty to investigate further absent clear defects. Knowledge of the verification file could not be imputed because the return itself gave no hint of the income item.