Question juridique clé
Whether the appellants had standing to challenge the land gain tax assessment and tax lien.
Solution extraite
Yes. As co-owners of the encumbered property, they could file the federal public law appeal and were entitled to object after the tax lien procedure had been opened.
Motifs extraits
The court held that owners burdened by a tax lien must be able to resist threatened enforcement like the taxpayer, and cantonal law expressly allows subsequent objection.