Questione giuridica chiave
Whether the tax security order was a valid definitive enforcement title despite an appeal against it.
Decisione estratta
Yes. A tax security order is immediately enforceable and has the same effect in enforcement as an enforceable judgment; the pending appeal did not stay enforcement.
Motivazione estratta
Under Art. 169 DBG and § 194 StG, a security order is immediately enforceable and an appeal does not suspend execution. Definitive enforcement depends on enforceability, not formal finality.