Questione giuridica chiave
Whether the appeal was admissible as administrative judicial review or as constitutional complaint
Decisione estratta
For tax periods before 1 January 2001, the appeal was not admissible as administrative judicial review but could be heard as a constitutional complaint.
Motivazione estratta
The Federal Tax Harmonization Act was not yet directly enforceable for earlier periods; however, the requirements for a constitutional complaint were met.