Question juridique clé
Whether the objections against the 2005 and 2006 official assessments were admissible despite lacking proof of manifest inaccuracy.
Solution extraite
The objections were inadmissible because the taxpayers did not substantiate, with evidence, that the official assessments were manifestly incorrect.
Motifs extraits
Under Art. 132(3) LIFD, an objection to an official assessment must be reasoned and supported by evidence. The taxpayers' filings were treated as objections but were not accompanied by proof; repeated requests to produce supporting documents were ignored, so the tax authority could declare them inadmissible.