Questione giuridica chiave
Whether the appellants had standing to challenge the land gain tax assessment and tax lien.
Decisione estratta
Yes. As co-owners of the encumbered property, they could file the federal public law appeal and were entitled to object after the tax lien procedure had been opened.
Motivazione estratta
The court held that owners burdened by a tax lien must be able to resist threatened enforcement like the taxpayer, and cantonal law expressly allows subsequent objection.