Key legal question
Whether the objection against the estimated property gain tax assessment was admissible without reasons and evidence.
Extracted holding
No. In an estimated assessment, the taxpayer had to show obvious incorrectness and name evidence within the objection period; a mere announcement that reasons and evidence would follow was insufficient.
Extracted reasoning
Art. 137(4) StG and the harmonized federal rules make a substantiated objection a validity requirement. Because the taxpayer did not comply, the tax authority correctly refused to enter into the objection.