Question juridique clé
Whether the complaint against the cantonal tax appeal judgment was admissible under Art. 86 BGG
Solution extraite
The cantonal tax appeal court could serve as a direct federal-court instance despite not being an upper court in the usual sense, so the complaint was admissible.
Motifs extraits
For certain federal tax regimes, the previous specialized cantonal appeal commission system was deliberately retained; Art. 86(2) BGG allows other judicial authorities required by federal law.