Dismissal of the appeal against the supplementary tax ruling for direct federal tax for the years 1997 to 1999

Facts

The [X. AG] was registered in the commercial register in 1989 and aimed to operate an office for architecture, engineering, planning, and general planning. In 2002, house searches were conducted at [X. AG] , during which files were seized and handed over to the tax administration of the canton of Bern. The tax administration initiated a supplementary tax and tax evasion procedure and issued a supplementary tax ruling for direct federal tax for the years 1997 to 1999. [X. AG] lodged an objection, which was rejected by the tax administration. The Tax Appeals Commission of the canton of Bern dismissed [X. AG] 's appeal.

[X. AG] requested the Federal Court to revoke items 2, 4, 6, and 7 of the decision of the Tax Appeals Commission of the canton of Bern, as well as the objection ruling of the tax administration of the canton of Bern.

Considerations

The Federal Court examined the appeal and found that the Tax Appeals Commission of the canton of Bern had rightly dismissed the appeal. [X. AG] had not kept its accounting records in order, and the tax administration had therefore had to conduct a supplementary tax procedure. The tax administration had estimated the tax factors in accordance with its due discretion, and [X. AG] had not proven that this estimate was obviously incorrect.

The Federal Court also rejected [X. AG] 's complaint that the Tax…