Questão jurídica principal
Whether the filing could be treated as a subsidiary constitutional complaint against the remission decision
Decisão extraída
Only a subsidiary constitutional complaint was conceivable, because an ordinary public-law appeal against tax remission decisions is excluded.
Fundamentação extraída
Appeals in public law against remission decisions are inadmissible under Art. 83 lit. m BGG, leaving only Art. 113 ff. BGG as a possible route.