Questão jurídica principal
Whether the missed appeal period should be restored due to illness
Decisão extraída
The taxpayers did not prove that illness prevented them from acting in time or from instructing a third party, so restoration was denied.
Fundamentação extraída
A medical certificate must explain the nature and concrete extent of the incapacity. Mere reference to illness or work incapacity is not enough, especially where the claimed impairment lasted over two and a half years. The authority could therefore treat the certificate as insufficient and refuse restoration.