Questão jurídica principal
Whether the cantonal tax office was properly acting as prosecuting authority in tax penalty proceedings under § 235 StG.
Decisão extraída
The cantonal tax office has the role of prosecuting authority in proceedings for fines for breach of procedural duties under tax law.
Fundamentação extraída
The court referred to the structure of § 235 StG and the corresponding federal rule, which assign the initial prosecutorial function to the tax authority.