Kernrechtsfrage
Whether the late objection against the 22 May 2000 interim assessment had to be admitted because the legal remedy instructions were misleading.
Extrahierter Entscheid
Yes. For lay taxpayers, the interim assessments and the accompanying instructions could be misunderstood as not being appealable, so the late filing could not be held against them.
Extrahierte Begründung
The documents did not clearly label the interim assessment as an appealable decision; the reverse-side instructions referred to assessment and objection decisions, used confusing terminology, and could lead laypersons to think no objection was possible. Under the principle of good faith, the authorities had to treat the objection as eligible despite the missed deadline.