Key legal question
Whether the appeal against the VAT decisions was filed in time despite the postal service fiction.
Extracted holding
The appeal was late because the decisions were deemed notified on the last day of the seven-day collection period, so the filing date could not cure the lateness.
Extracted reasoning
The factual finding that the postal notice was delivered on 2006-09-30 was binding; the collection fiction applies after seven days regardless of later actual pickup, and the appellant did not substantiate any error in that finding.