Key legal question
Whether the federal and cantonal tax appeal was filed in time despite different receipt dates by the spouses
Extracted holding
No. For spouses living in unseparated marriage, the objection period began with the first valid notice to the wife; the later receipt by the husband did not restart the deadline.
Extracted reasoning
Under the DBG and harmonized cantonal rules, communications to married spouses are addressed jointly, and a later separate copy to the other spouse does not create a second limitation period. The taxpayers' later changed account of the husband's receipt was not substantiated; in any event, their own conduct and the designation of the wife's address as representative address meant the authorities could rely on the first notice.