Kernrechtsfrage
Whether the 2003 estimated tax assessment could still be revised after becoming final.
Extrahierter Entscheid
No. The assessment had entered into final force, and no statutory ground for revision was shown; matters that could have been raised in the ordinary procedure cannot be revived by revision.
Extrahierte Begründung
Revision requires a statutory ground and is excluded for objections that should have been raised earlier with due diligence. The company could have challenged the estimated assessment within the ordinary appeal period.