Kernrechtsfrage
Whether the authority could amend the final 2008 assessment by correction to add omitted exit taxation
Extrahierter Entscheid
No. The omission was a misapplication of law in the original assessment, not a correctable clerical or recording error.
Extrahierte Begründung
A correction under § 169 Abs. 1 StG / Art. 150 Abs. 1 DBG is limited to calculation or writing mistakes, including certain software-related errors affecting expression. Here the authority knew the relevant facts, recorded the foreign residence, and simply applied the law incorrectly by not taxing the income after departure.