Question juridique clé
Whether the tax evasion fines were admissible despite the taxpayer's objections concerning the tax authority's investigative duty and prior order fines.
Solution extraite
The taxpayer's failure to file returns and to challenge the too-low discretionary assessments supported tax evasion; any breach of investigative duties could at most affect tax recovery, not criminal tax liability.
Motifs extraits
The causal link is assessed ex ante and is not broken in the evasion proceedings by possible faults of the tax authority; punishing the taxpayer does not amount to impermissible guilt compensation. Verfahrenspflicht violations and tax evasion are different offences, so ne bis in idem was not violated.