Kernrechtsfrage
Whether the undeclared child maintenance payments constituted new facts justifying a reassessment under Art. 151 DBG.
Extrahierter Entscheid
The maintenance payments were not known to the tax authority and were not so clearly apparent that they had to be treated as already known; they therefore qualified as new facts.
Extrahierte Begründung
The tax authority may generally rely on the taxpayer’s complete return and has no duty to investigate further absent clear errors or concrete indications. The prior file notes and the fact that the child lived in the household did not require the authority to infer continued payments.