Question juridique clé
Whether the subsidiary constitutional complaint was admissible despite no cognizable constitutional arguments and no legal entitlement to tax remission.
Solution extraite
The complaint was inadmissible because no violation of constitutional rights was properly alleged and the appellant lacked a legally protected interest for standing.
Motifs extraits
Subsidiary constitutional complaint requires specific pleading of constitutional rights; the appellant invoked none. In remission matters there is generally no legal claim to remission, so standing under Art. 115(b) BGG was lacking.