Questão jurídica principal
Whether cantonal ferie rules suspended the appeal period in direct federal tax proceedings
Decisão extraída
No. Cantonal ferie rules do not apply to complaint or appeal proceedings concerning direct federal tax; the appeal period was therefore not suspended.
Fundamentação extraída
For direct federal tax, the LIFD governs the appeal procedure and its deadlines are non-extendable; the federal regime does not provide ferie suspension. Harmonization does not justify applying cantonal ferie rules to federal tax appeals.