Questão jurídica principal
Whether the final direct federal and cantonal tax assessments for 2000-2002 had to be revised because of criminal judgments or alleged new facts.
Decisão extraída
No revision ground existed: the criminal convictions were unrelated to the tax assessments, and the alleged new facts were time-barred and in any event insufficient.
Fundamentação extraída
Under Art. 147 DBG and the parallel cantonal rules, revision requires a qualifying ground and compliance with the 90-day deadline. The cited criminal judgments did not influence the tax assessments, and the taxpayer invoked the alleged new facts too late.