Supreme Court dismisses dismissal of tax penalty proceedings when tax debt is enforced via bank account seizure.

The Supreme Court dismissed the taxpayer's request to terminate the proceedings regarding overdue tax penalties because the debt had already been enforced through a bank account seizure. The court held that administrative enforcement does not equate to voluntary payment and thus does not render the administrative proceedings for penalty dismissal without subject matter. Consequently, the lower court's decision to terminate the case was overturned to ensure the taxpayer's right to a substantive review of their request.