Question juridique clé
Whether the appeal against the tax security decision was admissible and whether the right to be heard was violated by insufficient reasoning.
Solution extraite
The appeal was admissible, and any initial defect in reasoning was cured during the federal proceedings.
Motifs extraits
Art. 169(3) DFTA allowed direct administrative appeal. The original decision briefly stated the essential reasons; the missing calculation details were supplied in the authority's submissions before the Federal Tribunal, and the appellant could respond.