Questione giuridica chiave
Whether the administrative appeal against the mutual legal assistance decision was filed within the statutory deadline
Decisione estratta
The appeal was late because the decision reached the bank-lagernd dossier on 23 April 2002, so the 30-day deadline expired before the filing on 30 July 2002.
Motivazione estratta
As an account holder without a Swiss service address, the decision was properly served only on the bank. Since the appellant had a bank-lagernd arrangement and no extended power of attorney was filed before the final decision, service through the bank was valid and time started to run when the decision entered the bank-lagernd dossier.