Key legal question
Whether the complaint could also challenge the Federal Tax Administration's objection decision and whether a declaratory request was admissible.
Extracted holding
Only the Tax Appeal Commission's decision could be challenged; the appeal against the objection decision and the declaratory request were inadmissible.
Extracted reasoning
Because of the devolutive effect, the objection decision was no longer the object of review. A declaratory request was barred since a concrete tax decision already existed and the tax liability could be assessed on the basis of the concrete facts.