Questão jurídica principal
Whether revision should be admitted for the legal question under § 122(2) AO when a third party merely disputes receipt of the tax assessment notice by the addressee.
Decisão extraída
Yes. The complaint was admissible and well founded because the case raises a question of fundamental importance requiring clarification in revision.
Fundamentação extraída
The court held that the proposed question can clarify whether mere denial of receipt by an affected third party is sufficient to create doubts under § 122(2) AO, thereby triggering the authority's burden to prove service.