Question juridique clé
Whether the appeal against the direct federal tax imputed assessment was admissible and well-founded.
Solution extraite
The imputed assessment was lawful because the taxpayer failed to prove its obvious incorrectness and did not substantiate his position with complete evidence for the whole relevant period.
Motifs extraits
Under Art. 130(2) and 132(3) DBG, the taxpayer had to rebut the assessment comprehensively and within the objection period. The asset increase remained unexplained despite requests for evidence, and the submitted opening balance and annual accounts did not cover the full uncertainty period or disprove the estimate.