Kernrechtsfrage
Whether the objection against the estimated tax assessment was filed in time despite service to the company instead of its representative
Extrahierter Entscheid
The objection was late; service defects did not prevent the authorities from relying on the lapse of the objection period in the circumstances.
Extrahierte Begründung
A taxpayer may be represented, and notices should generally be served on the authorized representative. Here, however, the company had not filed a written power of attorney, the authorities had previously dealt with the representative, but the company itself was directly addressed in the reminders and assessment. As direct addressee, it had a duty to clarify the situation in good faith and could not simply rely on an assumed service error; its failure to open registered mail also weighed against it.