Kernrechtsfrage
Whether prosecution for attempted gift tax evasion was time-barred
Extrahierter Entscheid
The prosecution was not time-barred; under either possible starting point, the limitation period was timely interrupted and the absolute period had not yet expired.
Extrahierte Begründung
The relevant procedural history showed that the statutory interruption rules applied, and the decisive time period had not elapsed when the appealed decision was rendered.