Question juridique clé
Whether the requirements for revision of the 2012-2014 tax assessments were met
Solution extraite
No. The newspaper article invoked by the taxpayers was not a new fact, and no decisive evidence or overlooked fact by the authority was shown.
Motifs extraits
Revision is an extraordinary subsidiary remedy and cannot cure omissions that could have been raised in the ordinary procedure. The article merely reported an alleged erroneous assessment and did not contain new material facts. The records did not show any breach of the authority's duty of investigation, and the taxpayers themselves had not declared the income as a 40% taxable life annuity.