Questione giuridica chiave
Whether the Federal Supreme Court could hear an administrative appeal against a cantonal tax judgment concerning tax periods before the entry into force of the Tax Harmonization Act.
Decisione estratta
No; administrative appeal was unavailable because the disputed tax periods predated the entry into force of the Tax Harmonization Act, so only a constitutional complaint remained open.
Motivazione estratta
The Tax Harmonization Act allows administrative appeal only for matters governed by its relevant titles, and during the cantonal adaptation period such appeals are generally excluded. Since the case concerned tax periods from 1987 to 1992, the Act did not apply at all.