Questão jurídica principal
Whether the administrative law appeal was admissible regarding direct federal tax in a tax-evasion case decided by a cantonal criminal chamber.
Decisão extraída
No admissible federal-tax administrative appeal lay against this criminal-court decision; the challenged act was not a final cantonal tax-law judgment under federal direct-tax procedure.
Fundamentação extraída
Bern had chosen a criminal-track 'judicial assessment' model, but direct federal tax evasion must be pursued by tax authorities under the federal tax procedure. A cantonal criminal decision in that framework is not an appealable federal-tax judgment.