Facts
[A. AG] , a real estate company headquartered in [C.] /Canton of Bern, was subject to limited taxation in the Canton of Graubünden due to real estate ownership. The company sold a commercial property in [D.] on July 17, 2002. The Cantonal Tax Administration of Graubünden requested the company to submit the tax return for the year 2002. As the company failed to comply with the request, the tax administration imposed a fine and threatened a discretionary assessment. After the company also failed to comply with this request, the assessment authority conducted a discretionary assessment on June 13, 2003. The company filed an objection against the discretionary assessment and requested to be assessed according to the annual financial statements submitted with the objection as of May 31, 2002. The cantonal tax administration dismissed the objection, as the discretionary assessment could only be challenged on the grounds of obvious incorrectness. The Administrative Court of the Canton of Graubünden upheld the company's appeal and instructed the tax administration to re-evaluate the matter, taking into account the new evidence submitted with the objection.Considerations
The Federal Supreme Court confirmed the decision of the Administrative Court. It stated that in reviewing a discretionary assessment in…