Kernrechtsfrage
Whether new evidence submitted with an objection to an estimated tax assessment must be considered when deciding the objection.
Extrahierter Entscheid
Yes. In objection proceedings against an estimated assessment, the relevant file state is the one at the time of the objection decision, not the original assessment date.
Extrahierte Begründung
The objection is a full ordinary remedy; the statute requires the objection to be reasoned and to name evidence, which would be meaningless if new evidence could not be considered. No clear statutory basis exists for a cut-off at the assessment date.