Key legal question
Whether the old federal direct tax rules on tax evasion and back tax applied to the 1993/94 period.
Extracted holding
The former BdBSt applied to the back-tax assessment for the 1993/94 period, even though the DBG was otherwise the milder criminal law.
Extracted reasoning
Back tax is governed by the law in force for the tax period concerned; under BdBSt, back tax is linked to a tax-evasion finding.