Key legal question
Whether the administrative appeal against the cantonal final decision on direct federal tax was admissible in full
Extracted holding
The appeal was admissible only insofar as it concerned direct federal tax; to the extent it also attacked the state tax portion, the court did not enter into it for lack of final cantonal instance.
Extracted reasoning
For pre-2001 tax periods, the uniform cantonal instance requirement did not yet apply; however, the state-tax part was not cantonal-final.