Questione giuridica chiave
Whether the Lucerne document of 19 April 2012 was an appealable tax assessment decision formally opened to the taxpayer.
Decisione estratta
No. Without formal notification to the affected taxpayer, the document was only an internal factors communication and not an appealable decision.
Motivazione estratta
The taxpayer was never formally served the document; the later conduct of the Lucerne authorities showed they did not regard it as a binding assessment fixing tax liability. Therefore there was no object capable of objection or appeal.