Question juridique clé
Whether the final 2001 tax assessment had to be reopened by revision
Solution extraite
Revision was denied because the asserted grounds could already have been raised through the ordinary appeal against the objection decision.
Motifs extraits
Revision under cantonal law and the harmonization rules is exceptional and barred where the alleged defects could have been invoked earlier with reasonable diligence; a revision route cannot extend the ordinary appeal deadline.