Question juridique clé
Whether the tax collection summons constituted a final administrative decision enforceable under the intercantonal concordat.
Solution extraite
No. The summons was only a reminder to pay an already due obligation and did not itself fix the tax debt in a binding, challengeable decision.
Motifs extraits
A title under the concordat requires a final decision assimilated to an enforceable judgment. The summons of 29 April 2004 was not a decision on the existence or amount of the debt and was not appealable.