Key legal question
Whether the taxpayer could obtain revision of final tax assessments for 2001-2003 based on the later legal change and equal-treatment arguments.
Extracted holding
No. A revision under cantonal and harmonization law requires statutory revision grounds; a later change in law or new case law is not such a ground.
Extracted reasoning
The court held that revision under Art. 197 StG/SG and Art. 51 StHG serves to correct procedural defects or factual errors, not to enforce a different legal view. Identical wording with federal law calls for identical interpretation in the interest of vertical tax harmonization.