Key legal question
Whether the deadline for filing the objection against the withholding-tax refund decisions of 1990-1996 should be restored.
Extracted holding
Yes. The restoration request was timely only once the representative had the information needed to file a proper objection and refund request; the cantonal court took an overly formalistic view.
Extracted reasoning
The obstacle ended only when the representative had sufficient knowledge of the assessments and the documents needed to substantiate the refund claim. The 30-day restoration period runs from the point when the party can, with due diligence, also perform the missed act, not merely from awareness of the assessment decisions.