Kernrechtsfrage
Whether a wife’s cessation of self-employment justified an interim assessment for direct federal tax 1999/2000.
Extrahierter Entscheid
No. For spouses living in an unseparated marriage, the decisive factor is the couple’s total income; since it increased substantially, no material and lasting change requiring interim assessment was shown.
Extrahierte Begründung
An interim assessment under Art. 45 lit. b DBG requires a lasting and substantial change in the earning base. Here, the spouses are taxed as a single economic unit under Art. 9 Abs. 1 DBG, so the relevant comparison is the combined income. That income rose markedly, and the lower court’s factual findings were not manifestly incorrect.