Kernrechtsfrage
Whether the taxpayer's objection against the direct federal tax assessment was timely filed
Extrahierter Entscheid
The objection was untimely because the assessment was deemed served on 13 April 1999, at the latest 16 April 1999.
Extrahierte Begründung
The Federal Court upheld the lower court's factual findings under the restricted review standard. The tax authority bore the burden of proving timely service and met it through documents, postal confirmation, and witness evidence; the taxpayer's contrary version was not sufficiently substantiated.