Key legal question
Whether the administrative law appeals were admissible when filed by the executor in his own name without a power of attorney from the heir.
Extracted holding
The executor had acted only as representative of the heir before the tax authorities and the cantonal court, so he could not switch to acting in his own name before the Federal Supreme Court; the appeals were inadmissible.
Extracted reasoning
The challenged tax decisions were addressed to the heir, who was the party to the lower-court proceedings. Although an executor may sometimes have party status, that did not matter here because he had appeared only as the heir's representative. Appearing in his own name at the federal stage would amount to an inadmissible change of party, and no power of attorney from the heir was produced.