Question juridique clé
Whether the Federal Tribunal could hear the direct federal tax appeal despite the absence of a cantonal second instance.
Solution extraite
No. Because the Jura system required a second cantonal appeal instance also for direct federal tax, the challenged decision was not rendered by the last cantonal instance and the federal appeal was premature.
Motifs extraits
Art. 145 LIFD, read with Art. 50 LHID, requires parallel cantonal appeal paths for direct federal tax and harmonized cantonal taxes when the canton has chosen a double-instance system. The Jura ordinance was contrary to federal law; therefore cantonal remedies were not exhausted.