Facts
Dr. med. A., born in 1950, worked as an employed anesthesiologist at the District Hospital V. from the 1990s until her retirement at the end of August 2014 and resided in U. ZH from 1995. For the periods 2004 to 2012, she failed to file a tax return despite reminders and was assessed for both the cantonal and the federal direct taxes based on discretionary assessment. In November 2014, A. requested a revision of the legally binding assessments for 2004 to 2012 from the Cantonal Tax Office of Zurich.
Considerations
The Federal Supreme Court concluded that the discretionary assessments from the period 2006 onwards are void. The tax assessment authority had grossly violated its duty to investigate and its obligation to make the assessments based on due discretion. Although it was aware at the latest after the first wage garnishment in December 2006 that the taxpayer's actual income was significantly…