Question juridique clé
Whether the federal appeal against the cantonal non-entry decision was admissible and could raise only the legality of non-entry.
Solution extraite
The appeal could be examined only as to whether the cantonal court unlawfully refused to enter into the case; merits arguments against the assessment itself were inadmissible.
Motifs extraits
Because the challenged decision was a procedural non-entry ruling, the Supreme Court could review only the alleged legal error in the refusal to enter, not the underlying tax assessment.