Questão jurídica principal
Whether the tax security order was a valid title for definitive debt enforcement despite pending challenge.
Decisão extraída
Yes. A tax security order is immediately enforceable and has the same effects in debt enforcement as an enforceable judgment; the pending appeal does not stay enforcement.
Fundamentação extraída
Under Art. 169 DBG and § 194 StG, the security order is immediately enforceable and an appeal does not suspend execution. Therefore, formal finality of the underlying tax decision is unnecessary for definitive legal opening.