Kernrechtsfrage
Whether the late payment of the court cost advance justified restoration of the time limit under Art. 24 VwVG.
Extrahierter Entscheid
No. The representative's reliance on email transmission problems and a third-party provider did not amount to an excusable impediment; the failure was attributable to the taxpayer and its representative.
Extrahierte Begründung
Electronic transmission is unreliable and required verification by other means. The representative had to monitor the provider and check whether the message actually reached the taxpayer. No clear absence of fault was shown.