Key legal question
Whether the filing before the cantonal court had to be treated as a complaint also against direct federal tax assessment
Extracted holding
No. The taxpayer designated the filing as a cantonal tax appeal and did not validly contest the direct federal tax decision in that proceeding.
Extracted reasoning
The legal remedies differ under cantonal law and federal tax law; the taxpayer was professionally represented and had expressly limited his challenge to cantonal tax matters. No excessive formalism occurred.