Kernrechtsfrage
Whether the 1991 cantonal tax reassessment was arbitrary because the commission was allegedly received for a third party under a trust or agency arrangement.
Extrahierter Entscheid
The taxpayer did not prove that the commission was received for a third party; the amount was therefore taxable to him and the reassessment was not arbitrary.
Extrahierte Begründung
The court found no clear proof of a contemporaneous written agreement and noted contradictions in the taxpayer's statements and documents. The burden of proving tax-reducing facts lay with the taxpayer.