Question juridique clé
Whether the objection against the estimated tax assessment met the enhanced reasoning requirements for challenging an assessment by estimation
Solution extraite
No. A mere subsequent tax return listing only Swiss real estate, without assets, income, or concrete evidence, did not satisfy the requirement to allege obvious incorrectness and name evidence.
Motifs extraits
For objections against an estimated assessment, the taxpayer must file a timely, qualified objection with reasons and at least a concrete offer of evidence; otherwise the authority must not enter into it.