Questione giuridica chiave
Whether the appeal against the remand decision was admissible despite lacking any showing under Art. 93 BGG.
Decisione estratta
The appeal was inadmissible because the appellant did not address the special requirements for challenging an interim remand decision and therefore failed to provide sufficient reasoning.
Motivazione estratta
Remand decisions are interim decisions. Such decisions can be challenged only under Art. 93 BGG, and the appellant bears the burden of showing those requirements. Since the tax authority said nothing about Art. 93 BGG, the appeal lacked the required reasoning under Art. 42(2) BGG and could not be considered under Art. 108(1)(b) BGG.