Questão jurídica principal
Whether the tax remission decision violated the taxpayer's right to be heard because it lacked reasons.
Decisão extraída
Yes. The decision contained no sufficient reasoning, so the taxpayer could not understand or challenge it properly.
Fundamentação extraída
A remission authority must briefly state the considerations on which it relied. A purely tabular calculation of open amounts and remitted parts, without explaining the criteria for partial rather than full remission, does not satisfy Art. 29(2) BV.