Key legal question
Whether the estimated assessment for direct federal tax was unlawful because the taxpayer had sufficiently documented his income and living expenses.
Extracted holding
The estimated assessment was justified because the taxpayer failed to provide reliable information and the assessment was not obviously excessive.
Extracted reasoning
Under Art. 130(2) and Art. 132(3) DBG, estimation is permitted when tax factors cannot be established reliably and may only be attacked for manifest error. The taxpayer did not disclose all income or expenses, so the authority was entitled to estimate income.