Questão jurídica principal
Whether the constitutional complaint against the tax remission and deferral refusals was admissible
Decisão extraída
No. The complaint was late, and the appellants lacked a legally protected interest because cantonal law left remission and deferral to the authority's discretion.
Fundamentação extraída
The remission and deferral decisions were final under cantonal tax law, but the federal complaint period had expired. In any event, no enforceable entitlement existed under Art. 224 StG, which confers exclusive discretion and sets no binding criteria.