Question juridique clé
Whether the administrative appeal against the federal tax security order was admissible and whether the taxpayer had standing.
Solution extraite
The appeal was admissible; the taxpayer, as direct addressee of the security order, had standing to challenge it.
Motifs extraits
Art. 169 Abs. 3 DBG expressly allows Verwaltungsgerichtsbeschwerde to the Federal Supreme Court within 30 days, and Art. 103 lit. a OG confers standing on the direct addressee.