Kernrechtsfrage
Whether Fribourg could reopen a final cantonal tax assessment by way of correction/revision or surtax after learning of the Bern assessment
Extrahierter Entscheid
No. The authority lacked a basis for revision, correction, or surtax because the relevant income and assets were not unknown facts arising after the assessment; the authority should have investigated or proceeded conditionally earlier.
Extrahierte Begründung
Revision and correction require the specific statutory grounds. A surtax presupposes previously unknown facts or evidence. Here the authority knew it lacked current information and should not have relied on outdated figures; it should have warned the taxpayers and, if needed, made a provisional assessment or sought the Bern data first.