Protection Against Irregular Notifications

Fernández Zubia Law Firm

Area: Tax Law
Case Type: Indirect amparo vs. desk audit order

Background

Estela Bayardo Osorio - In indirect amparo proceeding No. 513/2024, the desk audit order No. GIF6200002, contained in official letter No. 500-18-00-06-002024-1465 dated January 26, 2024, as well as its notice, was challenged.

Legal Strategy

The illegality of the notice was argued because it was served on a third party without the tax authority confirming that it was at the correct address.

Result Obtained

AMPARO GRANTED: The District Judge determined that the notice was served in a manner contrary to law and granted the amparo so that the notice would be set aside and all subsequent proceedings would have no effect. The review appeal is pending before the Collegiate Court of the Thirty-Second Circuit (docket 652/2024).

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