Key legal question
Whether the taxpayer's broader requests for a declaration of fiscal domicile, annulment of unidentified final assessments, and refund of paid taxes were admissible.
Extracted holding
Those requests were inadmissible because they were insufficiently precise and, in any event, a declaratory request was not available against the formative decision under review.
Extracted reasoning
The Court required concrete identification of the challenged assessments and a proper showing of a specific declaratory interest; neither was provided.