Questione giuridica chiave
Whether a subsidiary constitutional complaint is admissible against the refusal to remit direct federal tax.
Decisione estratta
The complaint is inadmissible because the taxpayer has no legally protected interest in remission of direct federal tax and therefore lacks standing under Art. 115 lit. b BGG.
Motivazione estratta
Although ordinary appeal was excluded, subsidiary constitutional complaint still requires a legally protected interest. In remission matters under direct federal tax, the taxpayer has no legal entitlement to remission; an arbitrariness claim alone does not create standing.