The right to initiate a tax assessment proceeding expires ten years after the end of the relevant tax period (statute of limitations). Once the proceeding has been initiated, the right to assess additional taxes expires fifteen years after the end of the relevant tax period (statute of limitations). The statute of limitations for fines for tax evasion is ten years.
In the case in question, the taxpayer appealed all the way to the Federal Supreme Court, specifically in the hope of reaching the fifteen-year statute of limitations, but without success, as the decision was rendered with unusual speed, within six months.
