Key legal question
Whether the guarantee demand under Art. 169 LIFD was justified despite the taxpayer's claimed move to Monaco.
Extracted holding
The tax claim was sufficiently plausible because the deceased likely kept her center of life in Ticino or at least stayed there long enough to remain subject to unlimited taxation.
Extracted reasoning
Hotel invoices, electricity usage and other indications made continued residence in Ticino plausible; the appellant offered no concrete proof of effective residence in Monaco. The court reviewed the matter only summarily, leaving definitive tax liability to ordinary tax proceedings.