Question juridique clé
Whether the administrative appeal against the security order was admissible despite prior payment of the secured amount.
Solution extraite
Yes. The taxpayer remained directly affected and had a current interest in review even after payment.
Motifs extraits
Art. 169(3) DBG allows an appeal against a security order; under Art. 103(a) OG the addressee is entitled to appeal, and post-payment does not eliminate current interest.