Questão jurídica principal
Whether the objection against the discretionary direct federal tax assessment sufficiently alleged obvious incorrectness under Art. 132(3) DBG.
Decisão extraída
No. A timely objection must itself set out the obvious incorrectness and name evidence; a later-filed tax return cannot replace that requirement.
Fundamentação extraída
The objection relied essentially on a tax return filed after the objection deadline. The taxpayers therefore failed to satisfy the duties of substantiation and evidence designation required to challenge a discretionary assessment.