Questão jurídica principal
Whether the appeal regarding direct federal tax was sufficiently reasoned and admissible.
Decisão extraída
It was inadmissible because the brief did not address the cantonal court's formal non-entry decision, focusing only on the merits.
Fundamentação extraída
When the lower court has dismissed a filing for lateness, the appeal must specifically challenge that procedural ground; a substantive discussion is not enough.