Facts
The appellant [X.] filed a claim with the Administrative Court of the Canton of Lucerne under Art. 85a DEBA and requested a declaration that the additional tax and penalty debt regarding the federal direct tax 1981-84 did not or no longer existed. The Administrative Court dismissed the claim, as the decision on the additional tax and penalty dated 15 January 1993 had been validly notified and had become legally binding. [X.] filed an administrative appeal against this judgment with the Federal Supreme Court.Considerations
The Federal Supreme Court dismissed the appeal. It stated that the decision on the additional tax and penalty dated 15 January 1993 had reached the appellant's sphere of control at the latest on 11 October 1993, when his legal representative collected a copy of it from the Administrative Court. Although the appellant had been informed about the legal remedies, he had not challenged the decision, so it had become legally binding. The appellant could not claim that the decision had never been validly notified, as he…