Kernrechtsfrage
Whether the objection against an estimated tax assessment met the heightened reasoning and evidence requirements
Extrahierter Entscheid
No. The objection had to be reasoned and supported by at least a concrete offer of evidence within the objection period; a mere later-filed tax return did not suffice.
Extrahierte Begründung
For objections to estimated assessments, the reasoning and evidence requirements are procedural prerequisites. Without a minimum objection statement, the tax authority must not enter into the objection.