Key legal question
Whether the complaint sufficiently challenged the denial of replacement acquisition for the 1999 special annual tax
Extracted holding
No. The appellants did not substantiate any arbitrary application of cantonal law or misapplication of the Tax Harmonization Act, nor did they challenge the factual findings properly.
Extracted reasoning
Federal appeals require concise reasoning and, for cantonal-law issues and factual findings, specific constitutional or federal-law arguments; the submissions were merely general assertions.