Questão jurídica principal
Whether the subsidiary constitutional complaint was admissible to challenge the refusal of remission on the merits.
Decisão extraída
The complaint was inadmissible insofar as it attacked the merits, because the taxpayer had no legally protected interest in remission of direct federal tax.
Fundamentação extraída
For direct federal tax there is no statutory entitlement to remission; therefore the willfulness objection alone does not confer standing under Art. 115 lit. b BGG.