Question juridique clé
Whether the appeal should be treated as administrative law appeal rather than state-law constitutional complaint.
Solution extraite
Because the dispute concerned cantonal income tax for a period governed by the Tax Harmonization Act, the filing was admissible as an administrative law appeal; constitutional review applied only subsidiarily to non-harmonized cantonal law.
Motifs extraits
The case fell within Art. 73 StHG after expiry of the adaptation period, even though the challenged decision relied directly on cantonal law.