Kernrechtsfrage
Whether the requested revision of the final tax assessment was admissible based on newly discovered evidence.
Extrahierter Entscheid
The revision request was inadmissible because the alleged evidence could and should have been produced during the original assessment proceedings with reasonable diligence.
Extrahierte Begründung
The bank transfer documents were accessible to the taxpayers in 2006, and the later expert report was not shown to have become available only later; revision cannot be used to reargue the earlier appreciation of evidence.