Questão jurídica principal
Whether a retroactive interim assessment as of 1 January 1993 could still be ordered
Decisão extraída
No. The conditions for an interim assessment could no longer be revisited because the relevant facts were already known when the earlier assessments and objections were decided, and those decisions had become final.
Fundamentação extraída
The prior assessments for 1992-1995, and the objections against them, were legally final. For both cantonal tax and direct federal tax, the separation/truly relevant facts did not justify reopening by interim assessment or revision.