Key legal question
Whether the subsidiary constitutional complaint was admissible to challenge the refusal of remission on the merits.
Extracted holding
The complaint was inadmissible insofar as it attacked the merits, because the taxpayer had no legally protected interest in remission of direct federal tax.
Extracted reasoning
For direct federal tax there is no statutory entitlement to remission; therefore the willfulness objection alone does not confer standing under Art. 115 lit. b BGG.