Question juridique clé
Whether the discretionary tax assessment under cantonal law was arbitrary or unlawful because the conditions for discretionary assessment were not met and the estimated business income was too high.
Solution extraite
The cantonal authorities were entitled to assess by discretion because the bookkeeping was incomplete and unreliable; the chosen income estimate based on the midpoint of the remaining uncertainty was not arbitrary.
Motifs extraits
The taxpayer did not substantively refute the findings that cash transactions were incompletely recorded and insufficiently documented. For cash-intensive small businesses, proper cash-bookkeeping is essential. The authorities were not required to choose the most favorable estimate for the taxpayer.