Supreme Court allows extraordinary review of tax decision due to 37-year administrative delay violating legal certainty.

The Supreme Court of Poland granted an extraordinary review of a tax decision regarding inheritance tax, overturning the lower court's dismissal of the taxpayer's appeal. The taxpayer argued the tax liability was time-barred because she lacked knowledge of the inheritance until after the five-year limitation period expired. The court found that the tax authority's failure to act for 37 years regarding the inheritance of the deceased's property constituted a grave violation of legal certainty and public interest, justifying the extraordinary review despite the statutory time limit.