Questão jurídica principal
Whether the cantonal tax office's letter of 29 November 2006 was an appealable decision
Decisão extraída
The letter contained the elements of a decision; lack of the label and appeal instructions did not prevent challenge, but the point did not change the outcome.
Fundamentação extraída
The office ruled on the refund request, assessed the taxpayer's payments and denied refund as time-barred; this went beyond a mere statement of opinion.