Key legal question
Whether the new factual allegations and documents submitted for the first time before the Federal Court had to be considered.
Extracted holding
No; the new allegations and evidence were inadmissible because they should have been raised earlier and the cantonal court had not violated essential procedural rules.
Extracted reasoning
Under the limited review of facts, new evidence is allowed only exceptionally. The taxpayer could reasonably have produced the corrected accounts already in the administrative or cantonal proceedings.