Kernrechtsfrage
Whether the final tax assessment could be revised under Art. 147 DBG based on alleged predominant private use of the property.
Extrahierter Entscheid
Revision was excluded because the alleged facts were known, or should have been known, during the original assessment proceedings and could have been raised then.
Extrahierte Begründung
Art. 147 DBG requires newly discovered decisive facts or evidence, or serious procedural defects, and revision is barred where the ground could have been invoked earlier with due diligence. The appellants relied only on facts available to them in the original proceedings; any mistakes by their former representative were attributable to them.