Questione giuridica chiave
Whether the 1998 addition of CHF 102,000 should be reduced because it was loan repayment rather than commission income.
Decisione estratta
The taxpayer failed to show that the estimated assessment was manifestly incorrect; the documents submitted did not displace the authority's finding that the payment was commission income.
Motivazione estratta
The taxpayer had business relations with Y., had previously earned commissions from him, Y. booked the payment as a commission, and there was no convincing evidence of an actual loan disbursement or security. At most, the documents raised doubts, which is insufficient under Art. 132(3) DBG.