Question juridique clé
Whether the Federal Administrative Court correctly held the appeal against the 1998 refund decision to be out of time despite the absence of a legal remedy notice.
Solution extraite
Yes. Even without a legal remedy notice, the decision had to be challenged within a reasonable time, which the appellant clearly exceeded by years.
Motifs extraits
The court relied on established case law requiring a challenge within a reasonable reflection period. The appellant waited more than 2.5 years to raise broader claims and almost 6 years to formulate specific objections, which was not reasonable.