Kernrechtsfrage
Whether the commuting cost deduction could be corrected through back-tax proceedings based on newly discovered facts
Extrahierter Entscheid
The correction was untimely; in this case, the tax authority could not adjust the commuting cost lump sum only in back-tax proceedings.
Extrahierte Begründung
For lump-sum commuting deductions, the practical-simplicity rationale requires that necessary clarifications be made, if at all, in the ordinary assessment stage. Where the authority did not use available clarification possibilities then, it cannot later replace the granted lump sum by back-tax assessment.