Questão jurídica principal
Whether the Federal Administrative Court could go beyond the taxpayer's request and annul the full tax assessment.
Decisão extraída
Yes. In administrative appeal proceedings, the appellate court may grant more than requested in the appellant's favor, as long as it stays within the dispute's subject matter.
Fundamentação extraída
Article 62 VwVG allows modification of the challenged decision in favor of a party; the court may therefore declare the whole assessed tax unlawful even if the appellant only sought a reduction.