El Tribunal Superior de Justicia de la Ciudad Autónoma de Buenos Aires resolvió en los autos “El Bagre Films SA s/ queja por recurso de inconstitucionalidad denegado en ‘El Bagre Films SA c/GCBA s/ impugnación de actos administrativos”, sentencia del 6/08/14, que el plazo de prescripción de las acciones y los poderes del Fisco para aplicar multas tributarias por omisión fiscal es de cinco años. Respaldó así lo decidido por la Sala I de la Cámara de Apelaciones en lo Contencioso Administrativo y Tributario.
Tomó esa decisión en el marco de un pleito en el que un contribuyente venía sosteniendo que las multas tributarias revisten naturaleza penal, y en consecuencia su plazo de prescripción estaría regido por el Código Penal de la Nación, que dispone que sea de dos años para hechos reprimidos con multa, y no por el Código Fiscal de la Ciudad, que fija un plazo de cinco años para determinar y cobrar tributos.
Los jueces José Osvaldo Casás, Ana María Conde y Luis Francisco Lozano coincidieron en sostener que el plazo de prescripción de las acciones de la Administración para imponer las multas fiscales es el mismo que tiene el organismo para determinar la obligación tributaria, es decir, de cinco años.
Señalaron que la circunstancia de que no esté expresamente previsto el plazo de prescripción para la imposición de multas tributarias no lleva a la solución que pretende la actora, ésto es la aplicación del Código Penal. Entre otras razones, fundaron esa decisión en una interpretación sistemática del Código Fiscal, y en las consecuencias perniciosas de aplicar plazos distintos para determinar deudas tributarias y las consecuentes sanciones por omisión fiscal.
Casás se refirió en sus argumentos a las prerrogativa de los Estados locales para tipificar y sancionar contravenciones, infracciones y faltas, en los ámbitos más variados y específicamente, en materia tributaria.
La juez Alicia E. C. Ruiz no suscribió la resolución por encontrarse en uso de licencia.
La juez Inés M. Weinberg se excusó de intervenir en este expediente por haber firmado la sentencia de fondo de la Sala I de la Cámara de Apelaciones en lo Contencioso Administrativo y Tributario.
Fuente: www.tsjbaires.gov.ar
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I will equipment this study towards Two designs of Those: recent Zune householders who are looking at an enhance, and humans striving in the direction of make a decision in between a Zune and an iPod. (There are other players worth considering out there, which includes the Sony Walkman X, yet I assume this provides oneself sufficient info in direction of create an knowledgeable final decision of the Zune vs players other than the iPod line as well.)
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Zune and iPod: Optimum us citizens assess the Zune in direction of the Contact, yet soon after watching how slim and incredibly lower and light it is, I look at it in direction of be a as a substitute exclusive hybrid that brings together qualities of both of those the Touch and the Nano. It’s Pretty vibrant and attractive OLED display screen is a little bit more compact than the touch screen, nevertheless the participant itself feels reasonably a little bit scaled-down and lighter. It weighs regarding 2/3 as much, and is drastically scaled-down in width and height, although remaining simply just a hair thicker.
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The Zune concentrates on remaining a Moveable Media Player. Not a website browser. Not a activity machine. Quite possibly within the potential it will do even better in individuals areas, yet for already it truly is a fantastic way to prepare and pay attention in the direction of your audio and videos, and is without the need of peer in that respect. The iPod’s strengths are its world-wide-web going to and apps. If these stable much more persuasive, possibly it is your excellent option.
The Zune concentrates upon getting a Transportable Media Player. Not a net browser. Not a match machine. Potentially in just the upcoming it’s going to do even improved within those people areas, nonetheless for already it is really a fantastic route towards organize and hear towards your new music and films, and is without the need of peer in that regard. The iPod’s rewards are its website traveling to and applications. If people solid added compelling, potentially it is your least complicated conclusion.
This is turning into a little bit a lot more subjective, nevertheless I substantially want the Zune Market. The interface is vibrant, consists of further more aptitude, and some cool capabilities together with ‘Mixview’ that allow for you all of a sudden check out similar albums, music, or other consumers identical in the direction of what you might be listening towards. Clicking upon a person of all those will center on that item, and one more preset of «neighbors» will arrive into viewpoint, allowing oneself to navigate around researching by comparable artists, music, or buyers. Conversing of buyers, the Zune «Social» is additionally fantastic pleasurable, permitting on your own discover many others with shared preferences and turning into mates with them. On your own then can listen toward a playlist manufactured based upon an amalgamation of what all your mates are listening to, which is much too remarkable. Individuals worried with privacy will be relieved toward know on your own can stay clear of the public in opposition to watching your specific listening behaviors if on your own as a result take.
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The Zune concentrates on staying a Portable Media Player. Not a internet browser. Not a sport machine. Quite possibly inside of the long run it’s going to do even much better within just those people areas, still for at the moment it can be a exceptional direction in the direction of prepare and listen in direction of your songs and movies, and is without having peer in that regard. The iPod’s advantages are its world wide web visiting and applications. If people strong even more persuasive, possibly it is your least difficult choice.
The clean Zune browser is shockingly favourable, nonetheless not as beneficial as the iPod’s. It performs properly, yet is just not as prompt as Safari, and has a clunkier interface. If yourself once in a while system upon having the world-wide-web browser that is not an issue, but if you happen to be designing towards read through the web alot from your PMP then the iPod’s bigger exhibit and better browser may possibly be major.
Arms down, Apple’s app store wins by a mile. It truly is a massive amount of all types of applications vs a rather not happy variety of a handful for Zune. Microsoft has Ideas, particularly in just the realm of games, but I’m not of course I’d want in the direction of guess upon the upcoming if this characteristic is important in the direction of oneself. The iPod is a considerably much better decision in just that situation.
Fingers down, Apple’s app retail store wins by means of a mile. It can be a massive selection of all forms of apps vs a pretty disappointed alternative of a handful for Zune. Microsoft includes Ideas, particularly inside of the realm of online games, yet I am not certain I might will need in direction of guess on the long term if this function is crucial to your self. The iPod is a substantially superior selection inside that scenario.
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Apple previously is made up of Rhapsody as an application, which is a suitable start out, however it is currently hampered by means of the inability in the direction of retail store domestically on your iPod, and consists of a dismal 64kbps little bit price tag. If this modifications, then it will to some degree negate this usefulness for the Zune, nonetheless the Ten new music for every thirty day period will nevertheless be a massive in addition within just Zune Pass’ prefer.
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