Kernrechtsfrage
Whether the deadline for the direct federal tax appeal should be reinstated
Extrahierter Entscheid
No reinstatement was granted because the taxpayers were not prevented by the statutory grounds from filing on time; their mistake about court holidays and deadline calculation did not qualify.
Extrahierte Begründung
The appeal deadline under the direct federal tax statute is governed exclusively by federal law; cantonal court holidays do not extend it. A foreseeable holiday absence and a legal mistake do not justify reinstatement.