Questione giuridica chiave
Whether the administrative law appeal against the tax security guarantee was admissible
Decisione estratta
The appeal was admissible in principle as filed in time against a final cantonal decision based on federal public law, subject to the statutory limits on review.
Motivazione estratta
Art. 169 cpv. 3 LIFD makes such guarantees challengeable; the Federal Tribunal reviewed facts and law ex officio because the decision was not judicial.