Questione giuridica chiave
Whether the final tax assessments for 2001-2009 could be revised on the basis of the later RDAC regulation and the Federal Tribunal's 2010 case law change.
Decisione estratta
No. A change in legislation or case law is not a new fact or evidence within the meaning of the revision rules; the taxpayers had to challenge the assessments by ordinary remedies.
Motivazione estratta
Revision under Art. 51 LHID and Art. 55 LPFisc is limited to procedural errors, overlooked facts, conclusive evidence, or criminal influence. New legal views, later jurisprudence, or a modification of case law do not qualify.