Question juridique clé
Whether the administrative law appeal was available against the cantonal tax judgment
Solution extraite
No. The contested decision was based exclusively on cantonal tax law, so the administrative law appeal was not open.
Motifs extraits
Art. 82 LPP and OPP 3 set mandatory principles, but the concrete cantonal tax assessment remained grounded in cantonal law; the then-unapplied LHID did not change that.