Key legal question
Whether a municipality may issue a declaratory decision determining a person's tax residence and unlimited tax liability.
Extracted holding
No. Municipalities have no authority to issue such declaratory decisions on tax residence; the decision is void.
Extracted reasoning
Under the cantonal tax act, only certain procedural decisions can be challenged separately, and tax liability may be treated as a separate proceeding only in specific intermunicipal allocation cases decided by the cantonal tax administration. A municipality is not competent to decide tax residence by declaratory decision.