Kernrechtsfrage
Whether a subsidiary constitutional complaint is admissible against the cantonal decision refusing full remission of direct federal tax.
Extrahierter Entscheid
The complaint is inadmissible because the taxpayer lacks a legally protected interest: there is no legal entitlement to remission of direct federal tax, so a mere arbitrariness claim is insufficient.
Extrahierte Begründung
Although ordinary federal public law appeal was excluded, admissibility of the subsidiary constitutional complaint still requires a legally protected interest under Art. 115 lit. b BGG. A remission authority's decision on direct federal tax is discretionary under Art. 167 Abs. 1 DBG, so the taxpayer has no enforceable right to remission.