Key legal question
Whether definitive legal opening can be granted for default interest on state and municipal taxes without a specific tax-interest assessment or order
Extracted holding
No. For default interest on tax debts, definitive legal opening requires an enforceable interest assessment or equivalent decision fixing the rate and start date.
Extracted reasoning
The tax statutes and ordinance make the interest claim subject to an administrative decision; the interest bill is therefore itself a disposition that must be final before legal opening can be granted.