Questão jurídica principal
Whether the federal complaint was admissible as a constitutional complaint rather than an administrative appeal
Decisão extraída
The filing had to be treated as a constitutional complaint, because the case concerned cantonal taxes during the harmonization transition period and direct federal tax was not at issue.
Fundamentação extraída
The court held that Art. 73 StHG did not apply for the relevant tax period; only Art. 84 OG was available. The pleading requirements of Art. 90 OG applied, but any shortcomings could remain open because the complaint would fail in any event.