Question juridique clé
Whether the late objections to the 2007 direct federal tax assessment could be admitted under deadline restoration rules.
Solution extraite
The restoration requirements were not met because the taxpayer failed to prove that illness prevented timely filing and the medical certificate was too vague.
Motifs extraits
Art. 133(3) DBG requires proof of a preventing reason and filing within 30 days after its end. The certificate did not sufficiently explain the incapacity or the timing of the illness; the court found no manifestly incorrect fact-finding.