Question juridique clé
Whether the federal administrative appeal was admissible without a final cantonal decision
Solution extraite
The appeal was not admissible because a cantonal final instance had not yet been provided for this type of direct federal tax dispute.
Motifs extraits
Following the Court's earlier ruling 2A.355/2003, cantons that provide an additional cantonal appeal instance for harmonized taxes must also open that path for direct federal tax from 2001 onward; therefore the present matter lacked the required final cantonal decision.