Questão jurídica principal
Whether the taxpayer's broader requests for a declaration of fiscal domicile, annulment of unidentified final assessments, and refund of paid taxes were admissible.
Decisão extraída
Those requests were inadmissible because they were insufficiently precise and, in any event, a declaratory request was not available against the formative decision under review.
Fundamentação extraída
The Court required concrete identification of the challenged assessments and a proper showing of a specific declaratory interest; neither was provided.