Questão jurídica principal
Whether the administrative judicial appeal concerning direct federal tax was sufficiently reasoned and therefore admissible.
Decisão extraída
No. The appeal did not address the dispute in a case-specific way and failed to show any revision ground or error regarding limitation issues.
Fundamentação extraída
Under Art. 108(2) OG the appeal must contain requests and a reasoning tied to the contested matter. General criticism and references to another case did not satisfy that requirement.