Questão jurídica principal
Whether the right to be heard was violated because the buyers were allegedly not invited to comment on the tax authority's appeal.
Decisão extraída
No violation was found because the buyers had later received notice of the proceedings and were specifically invited to submit documents and comments, but did not react in time.
Fundamentação extraída
Any earlier defect became irrelevant in light of the later notice; the buyers could and should have intervened once they learned of the pending case, and silence after that point was contrary to good faith.