This study deals with the behavior of the actors in the Austrian appeal procedure for tax matters in the light of changes in the interest level. The underlying question is whether and to what extent the appeal behavior of taxpayers on the one hand and the examination and reopening behavior of the tax office on the other changed over time. For this purpose, all Federal Fiscal Court decisions for a series of tax periodization effects were collected and compared with the development of the interest rate level over time using a regression analysis with regard to the occurrence of several characteristics of interest, such as the type of income, the disputed facts or the supreme court appeal.