Questione giuridica chiave
Whether the filing should be treated as a constitutional complaint rather than an inadmissible administrative-law appeal
Decisione estratta
The administrative-law appeal was inadmissible, but the filing was treated as a constitutional complaint against the final cantonal decision.
Motivazione estratta
The dispute concerned a pre-2001 tax period and thus did not involve federal administrative tax law review; however, the challenged cantonal final decision based on cantonal procedural law was open to constitutional review.