Kernrechtsfrage
Whether the 11 May 2006 request to revise the federal direct tax assessments was admissible because of the 16 December 2005 Vaud judgment and the changed Dumont practice.
Extrahierter Entscheid
The later judgment was not a new fact or conclusive evidence; a change in case law does not justify revision, and the assessments could no longer be reopened on that basis.
Extrahierte Begründung
Revision under Art. 147 LIFD requires newly discovered facts or evidence, or serious procedural defects. A subsequent judgment applying a new practice is not a revision ground, and the alleged inequality does not override the force of res judicata.