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... explaining that due to the special legal nature of penalties, they have priority in repayment on a par with taxes. The reasons for the transfer of the cassation appeal to the Supreme Court were not established. Then Agrotorg decided to appeal to the Constitutional Court, believing that paragraph 3 of Article 137 of the GOITRE already regulates the repayment of taxes and penalties. It says that they are repaid after the satisfaction of the collateral creditor's claims on the principal debt and interest on it. The Organization considers this approach applicable to the present issue. As noted by Agrotorg, the ...
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