Key legal question
Whether the security order was admissible and the tax claim appeared endangered under Art. 169 DBG.
Extracted holding
The appeal was admissible, but the tax payment objectively appeared endangered on a prima facie assessment.
Extracted reasoning
Persistent large arrears, admitted repayment difficulties, reduced income, sale of the home, possible relocation abroad, and delay in filing the 2004 return constituted sufficient indicators of tax risk.