Questione giuridica chiave
Whether the tax security order was unlawful or excessively high
Decisione estratta
The security order was upheld; the appellants failed to show a constitutional violation or that the amount was manifestly excessive.
Motivazione estratta
For tax security, a security ground, probable tax debt, and no obviously excessive amount are sufficient. The appellants' arguments about foreign assets and inability to pay did not affect the amount, which depends on the probable tax claim, not on their liquidity. The foreign residence itself constituted a statutory security ground.