Presumed service of administrative acts under § 122(2) AO and requirements for fundamental significance in fiscal proceedings

The German Federal Constitutional Court (First Senate, First Chamber) denied the applicant’s request for legal aid and refused to accept the constitutional complaint for decision, upholding the lower court’s position. The case involved a dispute concerning the presumed service of an administrative act under § 122(2) of the Fiscal Code (AO) and the requirements for admitting a constitutional complaint on the grounds of fundamental significance within fiscal court proceedings. The Court based its decision on § 93d(1) sentence 3 of the Rules of Procedure of the Federal Constitutional Court (BVerfGG), determining that the intended legal action had no prospect of success, resulting in a final, unappealable non-acceptance order without detailed reasoning.