Kernrechtsfrage
Whether the new factual allegations and documents submitted for the first time before the Federal Court had to be considered.
Extrahierter Entscheid
No; the new allegations and evidence were inadmissible because they should have been raised earlier and the cantonal court had not violated essential procedural rules.
Extrahierte Begründung
Under the limited review of facts, new evidence is allowed only exceptionally. The taxpayer could reasonably have produced the corrected accounts already in the administrative or cantonal proceedings.