Key legal question
Whether undeclared estate income for direct federal tax had to be allocated to the heirs according to inheritance shares under Art. 10 DBG.
Extracted holding
Yes. The tax arrears had to be borne by the heirs entitled to the undeclared estate in proportion to their inheritance shares, i.e. one quarter each among the relevant family branches.
Extracted reasoning
Art. 10 DBG requires attribution to individual heirs according to legal or testamentary shares. The heirs remained co-owners of the undeclared estate assets until partition, so the income belonged to the inheritance community, not to the persons who managed the assets.