Key legal question
Whether the appeal met the federal pleading requirements sufficiently to be examined on the merits.
Extracted holding
The court left the admissibility question open, because the appeal had to fail on the merits in any event.
Extracted reasoning
The court considered the criticism potentially understandable as a challenge to the interpretation of the cantonal ordinance as conflicting with higher federal tax law, but did not need to decide admissibility definitively.