Kernrechtsfrage
Whether the inheritance tax assessment for A Z's estate was time-barred
Extrahierter Entscheid
The five-year period for limited tax liability had not expired because the competent cantonal tax office only learned of the inheritance on 2018-01-10; the assessment of 2018-03-13 was therefore timely.
Extrahierte Begründung
The court held that knowledge by the income/wealth tax assessment unit could not be imputed to the separate unit competent for inheritance tax. For inheritance tax, § 241 Abs. 2 StG requires notification to the cantonal tax office; mere declaration in ordinary tax returns is insufficient, unlike the explicit rule for gift tax.