Questão jurídica principal
Whether the administrative appeal concerning direct federal tax and 2001/2002 cantonal tax was admissible and well founded against the refusal of revision.
Decisão extraída
The revision request failed because no new decisive facts or proof were shown, and the taxpayer could have raised the relevant objections earlier with reasonable diligence.
Fundamentação extraída
The 2003B instructions were not a new fact; prior forms and tax notices already indicated the use of presumed foreign income and wealth for rate purposes. The taxpayer should have checked the assessments and inquired in time. Revision cannot be used to cure omitted ordinary objections.