Key legal question
Whether the cantonal remand decision was a final decision open to federal appeal
Extracted holding
The remand left the tax authority with discretionary room and was therefore an interlocutory decision, not a final decision.
Extracted reasoning
A remand is only a final decision when the lower authority has no decision-making room and merely has to implement a higher-court order mechanically. Here the order required clarification, review, and possible redetermination of the refund, so discretion remained.