Questione giuridica chiave
Whether the subsidiary constitutional complaint is admissible despite no enforceable right to tax relief
Decisione estratta
The complaint is inadmissible because the applicant lacks a legally protected interest; tax-relief provisions grant no substantive entitlement and the arguments attack the merits rather than procedural rights.
Motivazione estratta
For tax-relief decisions, neither cantonal law nor federal law confers a claim. Art. 6(1) ECHR does not apply, and arbitrariness alone does not create standing absent a legal right. The alleged hearing defects were in substance challenges to the assessment of the merits.