Question juridique clé
Whether the appeal against cantonal tax for periods before 2001 was admissible by administrative law appeal.
Solution extraite
It was inadmissible because administrative law appeal was unavailable for tax periods before 1 January 2001; conversion into a constitutional complaint also failed.
Motifs extraits
Before tax harmonization became applicable, cantonal tax law did not have to comply with the Tax Harmonization Act, so no federal administrative-law violation could be invoked; the pleading also did not meet constitutional complaint requirements and, in any event, the remitted decision was an interlocutory order without irreparable harm.