Questão jurídica principal
Whether the subsidiary constitutional complaint met the admissibility and reasoning requirements of the Federal Supreme Court Act.
Decisão extraída
The complaint was inadmissible because it contained no request and no sufficiently substantiated legal reasoning challenging the remission refusal.
Fundamentação extraída
Under Art. 42 BGG a complaint must state its requests and reasons; the applicants merely asked for deferral until a planned house sale, which was a new request that had first to be raised before the tax authority. In a subsidiary constitutional complaint, only constitutional rights may be examined and only if expressly alleged.