Questão jurídica principal
Whether the tax office had to enter into the revision request despite missing proof of compliance with the statutory deadline
Decisão extraída
No. A revision request must be timely and properly substantiated by the taxpayer; the submissions did not show compliance with the 90-day deadline.
Fundamentação extraída
The burden was on the taxpayers to file a duly reasoned request within the statutory period. Their filings lacked the necessary explanation and evidence on timeliness, even after the tax office pointed them to the relevant rules.