Questão jurídica principal
Whether the estimated tax assessments for 2004, 2006 and 2007 were obviously incorrect and could be overturned.
Decisão extraída
No; the taxpayer failed to satisfy procedural duties despite warnings, and the new tax returns and property accounts filed only before the Federal Supreme Court could not be considered.
Fundamentação extraída
The taxpayer bears a general duty to cooperate and must produce records. In estimation assessments, an objection must be specifically reasoned and supported by evidence. New facts and evidence are excluded at the Federal Supreme Court stage, and accepting them would reward dilatory conduct.