Kernrechtsfrage
Whether the 2010 tax assessment could be revised based on newly discovered facts or decisive evidence.
Extrahierter Entscheid
No. The taxpayer did not present materially new facts or evidence; the underlying facts had already been known, and the later judgment only reappraised them legally.
Extrahierte Begründung
Revision under § 165 Abs. 1 lit. a StG and Art. 147 Abs. 1 lit. a DBG requires genuinely new and material facts or evidence. The taxpayer knew the relevant circumstances during the ordinary proceedings and could have objected then. Revision cannot be used to cure missed remedies.