Key legal question
Whether the right to assess direct federal tax 1997/1998 was time-barred
Extracted holding
The limitation period was interrupted by the cantonal tax office's letter of 25 August 2003, so assessment was not time-barred.
Extracted reasoning
Under Art. 120 DBG, the relative five-year assessment limitation can be interrupted by an official communication brought to the taxpayer's attention that seeks to establish or assert the tax claim; the letter expressly stated that the authority was maintaining the claim and served to interrupt limitation.