§ 2 Verordnung des Regierungsrates zum Bundesgesetz über die direkte Bundessteuer (DBG) - Departement

A 2021 21 · zg (Art. 2 Abs. 1 EV DBG)

Tax Remission Denial Based on Insufficient Financial Hardship and Preferential Creditor Payment

Cited as the standard used to determine whether the appellant was in financial hardship (Notlage), though the court ultimately found the conditions were not met.

100 2021 273 · be (Art. 2 Abs. 2 EV DBG)

Tax Abatement Refused Despite Current Hardship Due to Past Ability to Pay

Cited in the reasoning defining financial hardship for federal taxes (not cited in dispositive, but cited in reasoning).

100 2021 273 · be (Art. 2 Abs. 3 EV DBG)

Tax Abatement Refused Despite Current Hardship Due to Past Ability to Pay

Cited in the reasoning linking subsistence minimum to federal tax relief (not cited in dispositive, but cited in reasoning).

C/22120/2019 · ge (Art. 2 LIFD)

Tax Payment Order Opposition Lifting: Misidentification of Creditor

Cited in the reasoning section to support the court's decision to rectify the applicant's status from the Confederation to the Canton (the actual creditor).

B.2018.255 · sg (Art. 2 DBG)

Taxpayer Liable for St. Gallen Taxes Despite Claimed Foreign Residences

Provision cited in the reasoning (impliedly via Art. 3 Abs. 2 DBG) that defines tax residence, which forms the basis for the decision to dismiss the appeal.

B.2018.255 · sg (Art. 2 Abs. 2 DBG)

Tax Domicile Dispute: Spousal Presumption Upheld Against Appellant

Although Art. 3 Abs. 2 DBG is mentioned in the reasoning, the structure of the reasoning (referring to Art. 3 Abs. 1 DBG, Art. 3 Abs. 1 StHG, and Art. 13 Abs. 1 StG as the main grounds for liability) suggests that the core basis for the final decision on liability is found in paragraph 3.2.1. However, looking closely at section 3.4 which confirms the decision, it explicitly references the primary articles establishing liability (Art. 3 Abs. 1 DBG, Art. 3 Abs. 1 StHG, Art. 13 Abs. 1 StG). Since the court did not explicitly cite Art. 3 Abs. 2 DBG in its final dispositive orders (Order 1), I will check if any other provisions were cited in the dispositive, such as costs.

A 2007 35 · gr (Art. 2 Abs. 1 DBG)

Appeal Against Penalty Decisions for Attempted Tax Evasion (2003-2004)

This provision is implicitly referenced via Art. 176 DBG which concerns direct federal tax, as the decision addresses both cantonal and federal taxes.

VZ.2005.28 · sg (Art. 2 DBG)

Tax Enforcement Creditor Identity Dispute and Offset Claim Rejection

Cited to confirm that the Canton acts as the creditor for the collection of direct federal taxes.

VZ.2005.28 · sg (Art. 2 DBG)

Tax Execution Affirmation Against Taxpayer Rejecting Standing and Set-Off Defenses

Cited in the heading regarding the Cantons' role in collecting direct federal taxes.