Questão jurídica principal
Whether the complaint against the seizure notice was admissible despite the debtor not contesting the tax administration’s decision lifting the objection.
Decisão extraída
No. The debtor should have challenged the tax administration’s decision directly; that omission cannot be cured in the later enforcement complaint.
Fundamentação extraída
A continuation of enforcement based on a final decision that expressly removes the objection is lawful. Arguments such as set-off or a claimed tax credit must be raised before the tax administration and not for the first time in the seizure stage, where only enforcement defects can be reviewed.