Question juridique clé
Whether the discretionary tax assessment for 2001 and 2002 was obviously incorrect.
Solution extraite
No. The taxpayer did not show how he financed his living expenses, so the assessment of CHF 30,000 income could not be said to be obviously wrong.
Motifs extraits
Under the applicable harmonized tax rules, a discretionary assessment may be challenged only for obvious incorrectness. The taxpayer ignored requests to substantiate his living expenses and to identify supporting persons or loan agreements. The new allegation raised only before the Federal Supreme Court could not be considered.