Facts
Spouses [A.A.] and [B.A.] have their tax domicile in [U.] /SZ. The husband was self-employed as a farmer there from 1970 to 1998. For the 2003 tax period, the spouses had their tax return prepared by Dr. [B.] . He used the official software "eTax.schwyz" and included his address on the first page of the tax return. The taxpayers added their handwritten signatures at the bottom of the barcode sheet, immediately below the text block on the question of representation.
On 18 December 2006, the Tax Administration of the Canton of Schwyz issued the 2003 assessment decision and made offsetting calculations of CHF 186,160.--. The dispatch was made on 30 January 2007 and was addressed to [B.] . On 23 February 2007, [B.] filed an objection on behalf and on the instructions of the taxpayers. The objection authority later contacted [B.] in writing on 10 July 2014 and confirmed the offsetting. The taxpayers then filed a complaint with the Federal Supreme Court.
Considerations
The Federal Supreme Court notes that the lower instance was able to assume in accordance with federal law that the taxpayers had authorised [B.] to represent them in tax matters for the 2003 tax period within the meaning of Art. 117 of the Federal Act on Direct Federal Taxation (DFTA). The taxpayers had designated [B.] as their representative in their tax return and signed the barcode sheet with the power of attorney clause. From the overall circumstances, the authority…