Questione giuridica chiave
Whether the tax security order under Art. 169 DBG was justified by a risk to collection of the tax claim.
Decisione estratta
Yes. Existing loss certificates and the taxpayer's failure to file tax returns or otherwise cooperate made a risk to collection credible on a prima facie basis.
Motivazione estratta
Under Art. 169(1) DBG, security may be ordered whenever collection appears endangered based on the overall objective circumstances; no special conduct by the taxpayer is required. In summary proceedings, only a provisional review is made.