Questão jurídica principal
Whether the final 2001 tax assessment had to be reopened by revision
Decisão extraída
Revision was denied because the asserted grounds could already have been raised through the ordinary appeal against the objection decision.
Fundamentação extraída
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.