Kernrechtsfrage
Whether the 2004 district court judgment constituted a new fact justifying revision of the 1997 customs assessment under Art. 66(2)(a) VwVG.
Extrahierter Entscheid
No. The alleged procedural defects were known from the outset; the later legal assessment of those defects was not a new fact.
Extrahierte Begründung
Revision cannot be used to re-open issues that could have been raised in the original appeal proceedings, especially after the appeal deadline was missed. The factual circumstances were known already; only their later legal appraisal changed.