Key legal question
Which material law governed the assessment of income and fines for the tax years 1987-1992?
Extracted holding
The BdBSt applied as the material law for the income characterization and, for the fine, the milder version under Art. 129(1) BdBSt.
Extracted reasoning
The relevant facts occurred before the DBG entered into force, so the old federal decree governed; for the sanction, the court applied the milder rule because only slight fault was in question.