Kernrechtsfrage
Whether reassessment (tax arrears) for 2001-2003 could be imposed for direct federal tax despite the omitted interest being obvious in the original returns.
Extrahierter Entscheid
No. The omitted interest resulted from an obviously erroneous declaration that the tax authority should have corrected during the ordinary assessment; therefore the statutory prerequisite of new facts for reassessment was lacking.
Extrahierte Begründung
The taxpayer had disclosed the loan asset but failed to declare the accrued interest as income. Because the inconsistency was readily apparent, the authority had a duty to inquire further during the original assessment. It could not later cure its own omission through reassessment.