Questão jurídica principal
Whether the company committed attempted tax evasion for direct federal tax 2006
Decisão extraída
Yes. The undeclared profit share and related payments established an attempted tax evasion committed at least with conditional intent.
Fundamentação extraída
The gain arose in 2006 when the consortium was dissolved and amounts had already been paid; the company knowingly signed an incomplete return, and the evidence did not raise reasonable doubt.