Questão jurídica principal
Whether the security order under Art. 169 DBG was admissible and justified because the tax debt appeared endangered.
Decisão extraída
The authority had credibly shown a sufficient risk to the tax claim, so security could be ordered.
Fundamentação extraída
The court held that Art. 169 DBG requires only credible indication of objective danger to collection, not special misconduct. Years of undeclared income, concealed bank accounts, foreign ties, unclear residence, and movable assets justified the risk assessment.