Question juridique clé
Whether the missed appeal deadline should be restored under StG § 137 Abs. 2 because of family illness and lack of German.
Solution extraite
No. The hardships alleged did not make timely action impossible; lack of German and general workload or burden are not sufficient restoration grounds.
Motifs extraits
Restoration requires an actual impediment beyond the taxpayer's control. The mother’s illness and resulting burden were serious but did not prevent the taxpayer from opening mail or seeking translation help. Language difficulties do not constitute a restoration ground.