Questione giuridica chiave
Whether the cantonal tax office was properly acting as prosecuting authority in tax penalty proceedings under § 235 StG.
Decisione estratta
The cantonal tax office has the role of prosecuting authority in proceedings for fines for breach of procedural duties under tax law.
Motivazione estratta
The court referred to the structure of § 235 StG and the corresponding federal rule, which assign the initial prosecutorial function to the tax authority.