Auditor-Fiscal Da Receita Federal Practice Questions - Receita Federal Do Brasil - Auditor-Fiscal (AFRFB) Exam

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A commercial company receives a tax assessment notice (Auto de Infração) from the Receita Federal for alleged underpayment of IPI. Seeking to avoid immediate judicial tax execution while contesting the assessment, the company analyzes the statutory grounds for suspension of tax credit enforceability under Article 151 of the CTN. Which of the following legal events does NOT suspend the enforceability of a tax credit?

The timely submission of an administrative defense (impugnação) and administrative appeals within the Processo Administrativo Fiscal (PAF). The formal presentation of a private bank guarantee letter (fiança bancária) or judicial insurance bond (seguro garantia) prior to judicial tax execution. The full cash deposit of the disputed tax credit amount in an escrow account linked to administrative or judicial proceedings. The granting of an injunction (liminar) in a Mandado de Segurança or provisional injunctive relief (tutela provisória) in other judicial actions.

Correct Answer:

The formal presentation of a private bank guarantee letter (fiança bancária) or judicial insurance bond (seguro garantia) prior to judicial tax execution.

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