Kernrechtsfrage
Whether the tax authority proved the date of service of the assessment and whether the objection was timely.
Extrahierter Entscheid
The assessment was deemed served on 14 November 2016; the objection filed on 20 February 2017 was out of time.
Extrahierte Begründung
The authority bears the burden of proving service, but in mass-mailing cases proof may be established by all circumstances. A delay of more than two months was implausible, especially because a tax refund had already been paid in November 2016, which presupposed a definitive assessment.