If that judgment goes to appeal, the appellate court will have the opportunity to review both the precedent plus the case under appeal, Maybe overruling the previous case regulation by setting a different precedent of higher authority. This may well occur several times as the case works its way through https://casesofadministrativelaw69123.blogofchange.com/35413064/the-definitive-guide-to-case-law-on-tax-year-barred-by-time-income-tax