Kernrechtsfrage
Whether the joint notification of the 22 August 2006 reconsideration decision complied with Art. 113(4) DFTA despite the spouses' separate residences.
Extrahierter Entscheid
The joint notification was valid because the spouses had not clearly announced a legal or factual separation to the tax authorities and were still treated as living in common.
Extrahierte Begründung
Art. 113(4) DFTA requires joint addressing to married taxpayers living in common. The authorities could rely on the recorded marital status and address situation; the spouses bore responsibility for ensuring internal communication, and separate domiciles alone did not require separate service.