Question juridique clé
Whether the Federal Supreme Court could hear the appeal despite the cantonal tax administration not being a court during the transitional period under the BGG.
Solution extraite
The appeal was admissible under the transitional regime; the Federal Supreme Court left open the exact scope of factual review because it had no impact on the outcome.
Motifs extraits
The contested decision was rendered after 31 December 2006, so the BGG applied. Although the cantonal tax administration was not a court, Art. 130(3) BGG allowed federal review during the transitional period.