Key legal question
Whether the late administrative law appeal could be accepted for direct federal tax 2000.
Extracted holding
No; the appeal deadline was missed and the appeal was therefore inadmissible.
Extracted reasoning
The 30-day deadline under federal tax procedure had expired. The taxpayers' reliance on incorrect cantonal tax calculations concerned state and municipal taxes, not direct federal tax, so it did not constitute an excusable impediment for the federal appeal.