Key legal question
Whether the federal direct tax appeal was admissible despite the decision being issued before, but notified after, the cantonal appellate reform.
Extracted holding
The decision was treated as a last cantonal instance because the reform became applicable upon notification, so the direct appeal route was open.
Extracted reasoning
New procedural rules applied from 2007-07-01; when the decision was notified on 2007-08-16, the cantonal tribunal was no longer competent.