Kernrechtsfrage
Whether the right to tax the periods 1995/96 and 1997/98 was time-barred.
Extrahierter Entscheid
The limitation period had not expired; for 1995/96 it was suspended during the objection proceedings, and for 1997/98 the relevant tax assessment was timely notified.
Extrahierte Begründung
The taxpayer confused the date of the objection decision with the date of the assessment notice. For the earlier period, prescription did not run during the objection procedure and the absolute 15-year period had not elapsed.