811.1
STG
CH-SG
Art. 180 Steuergesetz (StG) - Einsprache a) Voraussetzungen
ZWEITER TEIL: STAATSSTEUERN - Sechster Abschnitt: Organisation und Verfahren - III. Veranlagung
Art. 180 StG · Einsprache a) Voraussetzungen
1. Gegen die Veranlagungsverfügung und die besondere Verfügung über die Grundstückwerte kann der Steuerpflichtige innert 30 Tagen seit der Eröffnung bei der Veranlagungsbehörde schriftlich Einsprache erheben.
2. Eine Ermessensveranlagung kann der Steuerpflichtige nur wegen offensichtlicher Unrichtigkeit anfechten. Die Einsprache ist zu begründen und muss allfällige Beweismittel nennen.
Gerichtsentscheide zu dieser Bestimmung (52)
B.2024.86.B.2024.87 · sg (Art. 180 Abs. 2 StG)
Tax Assessment Upheld Due to Undeclared Foreign Income
Cited in the context of the heightened burden of proof (obvious incorrectness) required to challenge an assessment made by estimation (Ermessensveranlagung) in the subsequent appeal process.
B.2024.37 · sg (Art. 180 Abs. 2 StG)
Tax Assessment Review Limited to Admission Decision Legality
The court confirmed the lower court's decision not to entertain the appeal because the formal requirements for the appeal against the discretionary assessment (substantiated reasoning and naming of evidence) were not met.
I.1.2022.280.281 · sg (Art. 180 Abs. 2 StG)
Company Fails to Justify Tax Assessment Objection Due to Procedural Defects
Cited in the dispositive as the basis for upholding the decision not to enter an appeal due to lack of substantiation regarding the obvious incorrectness of the discretionary assessment.
B.2023.102.B.2023.1 · sg (Art. 180 Abs. 2 StG)
Taxpayer Failure to Justify Discretionary Assessment Objection Upheld
Cited in the context of the necessary qualified reasoning required for an appeal against an assessment based on discretion (Ermessensveranlagung).
B.2023.230.B.2023.2 · sg (Art. 180 Abs. 2 StG)
Taxpayer Fails to Overturn Estimated Assessments Due to Lack of Procedural Compliance and Insufficient Objection Justification
Cited in connection with the limited review of a discretionary assessment and the requirement for reasoned objections.
B.2023.230.B.2023.2 · sg (Art. 180 Abs. 2 StG)
Taxpayer Appeals Against Discretionary Tax Assessments Dismissed for Lack of Substantiation
Cited in the reasoning regarding the required content of the objection against a discretionary assessment, which was the main issue for the non-entry decision.
B.2022.38.B.2022.39 · sg (Art. 180 Abs. 2 StG)
Taxpayer Challenge to Discretionary Tax Assessment Upheld
This article defines the limited scope of review for challenging a discretionary assessment (only due to obvious incorrectness), which was the core issue addressed in the decision.
B.2022.38.B.2022.39 · sg (Art. 180 Abs. 2 StG)
Taxpayer Appeal Against Discretionary Assessment Refusal Upheld
This article, alongside Art. 132 Abs. 3 DBG, establishes the procedural requirement for challenging a discretion-based assessment only due to obvious inaccuracy, which the appellant failed to meet, leading to the dismissal of the appeal.
I.1.2020.225.und.226 · sg (Art. 180 Abs. 2 StG)
Taxpayers v. Tax Authority Regarding Estimated Income Assessments
This provision establishes the requirement of 'obvious incorrectness' to challenge an estimation, which was the basis for upholding the non-admission of the appeal.
I.1.2021.18.und.19 · sg (Art. 180 Abs. 2 StG)
Taxpayer Appeal Against Refusal to Rule on Merits of Discretionary Tax Assessments
The appeal regarding cantonal taxes was dismissed because the appellant failed to meet the procedural requirement of providing a qualified justification and evidence against the discretionary assessment.
I.1.2020.225.und.226 · sg (Art. 180 Abs. 2 StG)
Taxpayer Challenge to Estimated Assessment Upheld Due to Lack of Substantiated Evidence
Cited in the reasoning that supports the decision to uphold the non-entry into the merits of the appeal due to insufficient substantiation of obvious incorrectness.
I.1.2021.18.und.19 · sg (Art. 180 Abs. 2 StG)
Tax Assessment Estimation Upheld Against Non-Compliant Company
Cited in relation to the requirement for a reasoned appeal against an estimated tax assessment, which was not met by the appellant.
I.1.2021.13.und.14 · sg (Art. 180 Abs. 2 StG)
Taxpayer Appeal Against Discretionary Tax Assessment Upheld
The appeal was dismissed because the objection against the discretionary assessment failed to meet the heightened formal requirements for substantiating the 'obvious incorrectness' as required by this provision.
I.1.2021.32.und.33 · sg (Art. 180 Abs. 2 StG)
Taxpayer v. Tax Authority: Failure to Substantiate Objection to Discretionary Income Tax Assessment
The appeal regarding Cantonal and Municipal Taxes was dismissed based on the reasoning that the appeal did not meet the formal requirements for contesting an assessment made by discretion, as stipulated by this article.
I.1.2021.13.und.14 · sg (Art. 180 Abs. 2 StG)
Taxpayer Appeal of Estimated Assessment Upheld Due to Lack of Records
The appeal was dismissed because the objection against the discretionary assessment did not meet the heightened formal requirements regarding substantiation of manifest incorrectness, as cited in the reasoning leading to the dispositive orders.