Key legal question
Whether the cantonal tax assessments for 1997 and 1998 were time-barred
Extracted holding
The assessments were not time-barred under either the old or the new Basel-Stadt tax law.
Extracted reasoning
Under the old law, the material law also governed limitation, and the assessments of 16 September 2004 were timely under the applicable ten-year relative assessment limitation. Even under the new law, the transitional rule could be interpreted so that the five-year period began on 1 January 2001, making the assessments timely as well.