Key legal question
Whether the complaint before the Federal Administrative Court met the reasoning requirements of Art. 52 VwVG.
Extracted holding
No. The submissions did not address the Nichteintretensentscheid in a case-specific way and therefore were insufficiently reasoned.
Extracted reasoning
The appellant criticized the merits of the estimated assessment, but the lower instance had refused to enter into the objection for formal reasons. Arguments directed only at the substantive assessment do not meet the requirement to challenge the formal inadmissibility reasoning.