Die Steuerhinterziehung durch Erwirken eines unrichtigen Grundlagenbescheides

The dissertation focuses on legal issues regarding tax evasion by obtaining an incorrect notice of assessment. In doing so, the thesis first analyses the procedural law, general issues in regard to § 370 AO as well as its legally protected interest. It then proceeds to discussing the new judicature of the German Federal Court in this respect. The author dissmisses the latter especially for it's infringement of the German constitutional law. The dissertation further discusses the practice-oriented Issues regarding the beginning of the attempt of tax fraud and the statute-barred prosecution that result of the new jurisdiction.
The author is currently working as a lawyer specialised in tax law. He used to work as a prosecuter in Munich.