Kernrechtsfrage
Whether the appeal to the cantonal tax appeal commission was filed within the statutory time limit after service of the tax office decision.
Extrahierter Entscheid
The commission could rely on service to the taxpayer's representative on 16 December 2003, so the 30-day period had expired before the appeal filed on 19 January 2004.
Extrahierte Begründung
The post receipt supported the commission's factual finding. The taxpayer's later objections did not displace that finding under the limited review of fact by the Federal Court.