Question juridique clé
Whether the security order under Art. 169 DBG was admissible and justified because the tax debt appeared endangered.
Solution extraite
The authority had credibly shown a sufficient risk to the tax claim, so security could be ordered.
Motifs extraits
The court held that Art. 169 DBG requires only credible indication of objective danger to collection, not special misconduct. Years of undeclared income, concealed bank accounts, foreign ties, unclear residence, and movable assets justified the risk assessment.