Facts
The spouses [A.A.] and [B.A.] have a tax domicile in [U.] /ZH. On 20 November 2018, the Tax Office of the Canton of Zurich (KStA/ZH) issued two provisional measures against the husband. One concerned the cantonal and municipal taxes of the Canton of Zurich, tax periods 2014 and 2015, the other the direct federal tax, tax periods 2007, 2008 and 2010 as well as 2014 and 2015.
The spouses appealed to the Administrative Court of the Canton of Zurich on 24 December 2018 and requested the cancellation of the provisional measures and the arrest orders. The Administrative Court dismissed the husband's legal remedies with a combined decision SR.2018.00025 / SR.2018.00026 of 29 May 2019.
The spouses filed a complaint with the Federal Court and requested that the contested decision be cancelled, or alternatively that the matter be referred back to the lower court in accordance with the considerations.
Considerations
The Federal Court examines federal law in principle ex officio and with unrestricted cognition. In proceedings concerning provisional measures, however, the Federal Court can only review the interpretation and application of federal laws and ordinances under the aspect of violation of constitutional individual rights.
The spouses complain that the provisional measures of 20 November 2018 were addressed only to the husband and that the lower court denied the complaining wife's standing. The Federal Court notes that the provisional measures serve to secure a presumed tax evasion fine against the husband and that the cantonal authorities accuse him of not declaring and thus evading daily allowances from an insurance company in the two periods.
The Federal Court comes to…