Questão jurídica principal
Whether the federal appeal against the cantonal inadmissibility ruling was sufficiently reasoned under Art. 42 LTF.
Decisão extraída
No. The appellant did not address the timeliness issue or the alternative merits reasoning, so the appeal failed the federal substantiation requirement.
Fundamentação extraída
The Federal Supreme Court only examines the challenged decision and the appellant raised no arguments against the decisive finding of tardiness nor against the alternative tax-law reasoning; therefore the appeal was manifestly insufficiently reasoned.