Question juridique clé
Whether the cantonal tax office had standing to file a criminal complaint appeal under Art. 81 BGG
Solution extraite
No standing: it was neither a civil claimant affected by civil claims, nor a complainant challenging a private prosecution right, nor a participating federal administrative authority in the sense of the VStrR.
Motifs extraits
For direct federal and cantonal tax offences, the VStrR does not apply; the tax office acted only as an informant and 'injured party representative', not as an authority conducting proceedings under the VStrR.