Notice 500-05-2024-25840 Communicating List of Taxpayers Who Challenged Presumption Notices or Resolutions Under Article 69-B of the Federal Tax Code and Had Them Declared Ineffective

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DOF: 07/02/2025

OFFICE 500-05-2024-25840 communicating the list of taxpayers who promoted some means of defense against the presumption notice referred to in the first paragraph of Article 69-B of the Federal Tax Code or against the resolution referred to in the fourth paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act without effect.

At the margin a logo, which says: Tax Administration Service.- General Administration of Federal Fiscal Audit.- Central Administration of Strategic Auditing.

OFFICE: 500-05-2024-25840

Subject: List of taxpayers who promoted

some means of defense against the presumption notice referred to

in the first paragraph of Article 69-B of the CFF or against the

resolution referred to in the fourth paragraph of the article in

question, and once resolved, the jurisdictional or

administrative body left the referred act without effect.

This Central Administration of Strategic Auditing, attached to the General Administration of Federal Fiscal Audit, of the Tax Administration Service, based on what is established by articles 16,

first paragraph of the Political Constitution of the United Mexican States; 1, 7, fractions VII, XII and XVIII and 8,

fraction III of the Law of the Tax Administration Service, published in the Official Gazette of the Federation

on December 15, 1995, reformed by Decree published in the same Official Gazette on

June 12, 2003; 1, 2, first paragraphs, section B, fraction III, subsection e) and second, 5, first paragraph,

13, fraction VI, 23, section E, fraction I, in relation with article 22 first paragraphs, fraction VIII, and

last, numeral 5 of the Internal Regulations of the Tax Administration Service, published in the Official

Gazette of the Federation on August 24, 2015, in force from November 22, 2015, in

conformity with what is established in the first paragraph of Article First Transitory of said Regulations, and

reformed through Decree by which various provisions of the Internal Regulations of the Ministry of Finance and Public Credit and of the Internal Regulations of the Service

of Tax Administration are reformed and added, and by which the Internal Regulations of the National Agency of Customs of

Mexico are issued, published in the same official organ on December 21, 2021, in force from January 01,

2022, in conformity with what is established in the First Transitory Article of said Decree; Article Third,

fraction I, subsection a), of the Agreement by which various attributions are delegated to the Public Servants

of the Tax Administration Service, published in the Official Gazette of the Federation on June 23,

2016, in force from July 23, 2016, in conformity with what is established in the First Transitory

Article of said Agreement; in articles 33, last paragraph, 63 and 69-B, sixth paragraph of the Fiscal Code of the

Federation, it communicates the following:

That to the taxpayers listed below, at some point, a Notice of

Presumption of non-existence of operations backed by certain fiscal receipts that

they issued was notified, this in accordance with the first and second paragraphs of article 69-B of the Fiscal Code of the

Federation, in relation with article 69 of its Regulations.

Following the procedure provided for in the aforementioned article 69-B of the Fiscal Code of the Federation, and in

terms of the fourth paragraph of the aforementioned article, the aforementioned taxpayers were notified of the

definitive resolution as indicated below:

Notification to taxpayers of the OFFICE OF THE DEFINITIVE RESOLUTION.

No.

R.F.C.

Name, denomination or legal name

of the Taxpayer

Number and date of definitive resolution office

Means of notification to the taxpayer

Authority's public notice board

Personal Notification

Tax Box

Date of

posting on the

Authority's

public notice board

Date on

which it was

notified in

Tax Box

Date of

notification

Date on

which the

notification took

effect

Date on

which it was

notified in

Tax Box

Date on

which the

notification took

effect

01

CAL140806DZ8

CORPORATIVO ALAYA, S.A. DE

C.V.

500-55-00-03-00-2019-956 of

date August 21, 2019

23 of

August

2019

26 of

August

2019

02

CSI151117RB6

COMERCIALIZADORA SIFAM,

S.A. DE C.V.

500-12-00-02-00-2019-07958

of date August 13, 2019

20 of

August

2019

21 of

August

2019

03

GEE100628A13

GRUPO ENLACE

EMPRESARIAL, S.A. DE C.V.

500-04-00-00-00-2020-16749

of date July 13, 2020

20 of July

of 2020

21 of July

of 2020

04

HEPS951229L82

HERNANDEZ PEÑA SANDRA

GUADALUPE

500-05-2023-26195 of date

06 of December of 2023

12 of

December

of 2023

13 of

December

of 2023

05

LNC101215CR3

" LA NORIA DE CULIACAN " , S.A.

DE C.V.

500-46-00-05-02-2019-10927

of date June 26, 2019

03 of July

of 2019

04 of July

of 2019

06

MAN1708282Q9

MANFIT, S.A. DE C.V.

500-27-00-08-02-2021-10841

of date August 30, 2021

03 of

September

of 2021

06 of

September

of 2021

07

MGO100409585

MRCI DEL GOLFO, S.A. DE C.V.

500-44-00-00-00-2020-08420

of date September 24

of

2020

30 of

September

of 2020

01 of

October of

2020

08

OOSF730812NA0

OSORIO SANTIAGO FORTINO

500-71-06-01-03-2020-64230

of date March 10, 2020

19 of March of

2020

15 of April

of 2020

09

QAE160811830

QARR ARRENDADORA DE

EQUIPOS, S.A. DE C.V.

500-74-05-04-01-2020-10911

of date March 05, 2020

11 of

March of

2020

12 of March

of 2020

10

TCT140331PXA

TECNO CUEROS Y TANINOS

CUPRA, S.A. DE C.V. // In

compliance with the sentence of

date May 03, 2023,

issued by the Second Regional

North-East Chamber of the State of

Mexico, of the Federal Tribunal of

Administrative Justice, in the

Nullity Trial 148/22-11-02-3-OT

500-25-00-05-01-2024-4325

of date February 23

of

2024

27 of

February of

2024

28 of

February of

2024

11

YAS151027P52

YESHER ASESORES, S.A. DE

C.V.

500-05-2020-23510 of date

16 of October of 2020

22 of

October of

2020

23 of

October of

2020

Additional data of the taxpayers.

No.

R.F.C.

Name, denomination or legal name

of the Taxpayer

Fiscal Address

Preponderant Activity

Reason for

Procedure

01

CAL140806DZ8

CORPORATIVO ALAYA,

S.A. DE

C.V.

ALCALDÍA CUAUHTÉMOC,

CITY OF MEXICO

CONSULTING SERVICES

IN ADMINISTRATION

Absence of assets,

Absence of personnel

02

CSI151117RB6

COMERCIALIZADORA SIFAM,

S.A. DE C.V.

ZAPOPAN, JALISCO

OTHER INTERMEDIARIES OF

WHOLESALE TRADE

Absence of assets,

Absence of personnel

03

GEE100628A13

GRUPO ENLACE EMPRESARIAL,

S.A. DE C.V.

MEXICALI, BAJA CALIFORNIA

OTHER PROFESSIONAL

SERVICES,

SCIENTIFIC AND TECHNICAL

Absence of assets,

Absence of personnel

04

HEPS951229L82

HERNANDEZ PEÑA SANDRA

GUADALUPE

JOSÉ MARÍA PATONI,

DURANGO

SALARIED

Absence of assets,

Absence of personnel,

Lack of material capacity

05

LNC101215CR3

" LA NORIA DE CULIACAN " ,

S.A.

DE C.V.

PUEBLA DE ZARAGOZA,

PUEBLA

CONSULTING SERVICES

IN ADMINISTRATION

Absence of assets,

Absence of personnel,

Lack of material capacity

06

MAN1708282Q9

MANFIT, S.A. DE C.V.

TAXCO DE ALARCÓN,

GUERRERO

OTHER INTERMEDIARIES OF

WHOLESALE TRADE

Absence of assets,

Absence of personnel,

Lack of material capacity,

Lack of Infrastructure

07

MGO100409585

MRCI DEL GOLFO, S.A. DE C.V.

OAXACA DE JUÁREZ, OAXACA

SUPPLY OF PERSONNEL

PERMANENT

Absence of assets,

Absence of personnel,

Lack of material capacity,

Lack of Infrastructure

08

OOSF730812NA0

OSORIO SANTIAGO FORTINO

ATIZAPÁN DE ZARAGOZA,

STATE OF MEXICO

WHOLESALE TRADE

OF WASTE PAPER AND

OF CARDBOARD

Absence of assets,

Absence of personnel

09

QAE160811830

QARR ARRENDADORA DE

EQUIPOS, S.A. DE C.V.

ALCALDÍA CUAUHTEMOC,

CITY OF MEXICO

RENTAL OF OTHER

REAL ESTATE

Absence of assets,

Absence of personnel

10

TCT140331PXA

TECNO CUEROS Y TANINOS

CUPRA, S.A. DE C.V.

LEÓN, GUANAJUATO

TANNING AND FINISHING OF

LEATHER AND SKIN

Absence of assets,

Absence of

personnel,

Lack of Infrastructure

11

YAS151027P52

YESHER ASESORES, S.A. DE

C.V.

ALCALDÍA GUSTAVO A.

MADERO, CITY OF MEXICO

WHOLESALE TRADE

OF FURNITURE

Absence of assets,

Absence of personnel,

Lack of Infrastructure

Therefore, the name or legal name of the taxpayers

to whom the aforementioned

resolutions were notified, were added to the list referred to in the fourth paragraph of Article 69-B of the Fiscal Code

of the Federation, which was published in the Official Gazette of the Federation, as indicated below:

No.

R.F.C.

Name, denomination or

legal name of the

Taxpayer

Number and date of office containing

in Global Definitive List

Date of publication in the

Official Gazette of the Federation

01

CAL140806DZ8

CORPORATIVO ALAYA, S.A. DE C.V.

500-05-2019-36127 of date 15

of

November of 2019

06 of December of 2019

02

CSI151117RB6

COMERCIALIZADORA SIFAM, S.A. DE C.V.

500-05-2019-33645 of date 06

of

December of 2019

26 of December of 2019

03

GEE100628A13

GRUPO ENLACE EMPRESARIAL, S.A. DE C.V.

500-05-2020-23449 of date 25

of

September of 2020

12 of October of 2020

04

HEPS951229L82

HERNANDEZ PEÑA SANDRA GUADALUPE

500-05-2024-6622 of date 15

of February

of 2024

31 of May of 2024

05

LNC101215CR3

" LA NORIA DE CULIACAN " , S.A. DE C.V.

500-05-2019-39139 of date 25

of

November of 2019

13 of December of 2019

06

MAN1708282Q9

MANFIT, S.A. DE C.V.

500-05-2021-26246 of date 25

of

November of 2021

15 of December of 2021

07

MGO100409585

MRCI DEL GOLFO, S.A. DE C.V.

500-05-2021-5055 of date 09

of February

of 2021

22 of February of 2021

08

OOSF730812NA0

OSORIO SANTIAGO FORTINO

500-05-2020-13692 of date 19

of June

of 2020

07 of July of 2020

09

QAE160811830

QARR ARRENDADORA DE EQUIPOS, S.A. DE C.V.

500-05-2020-13568 of date 13

of May

of 2020

29 of June of 2020

10

TCT140331PXA

TECNO CUEROS Y TANINOS CUPRA, S.A. DE C.V.

500-05-2024-6869 of date 17

of April of

2024

31 of May of 2024

11

YAS151027P52

YESHER ASESORES, S.A. DE C.V.

500-05-2021-5061 of date 09

of February

of 2021

24 of February of 2021

Dissatisfied with the individual presumption office or definitive resolution office, they filed means of

defense, which were concluded with the following resolutions or sentences:

No.

R.F.C.

Name, denomination

or legal name of the

Taxpayer

Means of defense

Date of the

Resolution or

final sentence

Authority that

resolved

Sense and/or effect of the resolution or

final sentence

01

CAL140806DZ8

CORPORATIVO ALAYA,

S.A. DE C.V.

Nullity Trial

19311/22-17-03-9

24 of November

of 2023

Third Regional

Metropolitan Chamber

of the Federal

Administrative Justice

Tribunal

The nullity of the impugned act 500-05-2019-36127 of date

15 of November of 2019, issued in

supplement for absence of the Central Administrator

of Strategic Auditing by the

Strategic Auditing Administrator " 7 " , only insofar as it concerns the

morality of Corporativo Alaya, S.A. de C.V.

02

CSI151117RB6

COMERCIALIZADORA

SIFAM, S.A. DE C.V.

Nullity Trial

1314/20-07-03-7

18 of March

of

2022

Third Regional

Chamber of

the West of the

Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution 500-12-00-02-00- 2019-07958 of date 13 of August of

2019, issued by the

Concentrated Administration of Fiscal Audit of

Baja California Sur "1" is declared.

03

GEE100628A13

GRUPO ENLACE

EMPRESARIAL,

S.A. DE

C.V.

Nullity Trial

3118/20-01-02-8

02 of March

of

2023

Second Regional

Chamber of

the Northwest I of the

Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution 600-09-00-02-2020- 2876 of date 28 of September of 2020,

issued by the

Concentrated Legal Administration of Baja

California "1", by means of which the

Administrative Recourse of Revocation was dismissed

Online, as well as the

originally appealed 500-04-00-00-00- 2020-16749 of 13 of July of 2020,

signed by the Central Administration of

Verification and Evaluation of Entities

Federative in Matters of Fiscal Coordination.

04

HEPS951229L82

HERNANDEZ PEÑA

SANDRA GUADALUPE

Administrative Recourse

of Revocation

RRL2024001423

20 of May

of

2024

Concentrated Administration

Legal of

Durango "1"

The appealed resolution 500-05-2023-26195 of date 06 of

December of 2023, issued by the

Central Administration of Strategic Auditing is left without effect.

05

LNC101215CR3

" LA NORIA DE

CULIACAN " ,

S.A. DE

C.V.

Nullity Trial

2185/19-12-02-5

11 of April

of

2022

Second Regional

Chamber of

the East of the

Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution 500-46-00-05-02- 2019-10927 of date 26 of June of 2019,

issued by the

Concentrated Administration of Fiscal Audit of

Puebla "2" is declared.

06

MAN1708282Q9

MANFIT, S.A. DE C.V.

Nullity Trial

791/21-14-01-3

23 of June

of

2022

Regional Chamber

of the Pacific and

Auxiliary of the

Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution is declared

500-27-00-08-02-2021-10841

of date August 30, 2021, issued

by the Concentrated Administration of

Fiscal Audit of Guerrero "1", for the effect that the authority requires the

taxpayer [ ... ] to issue the resolution that

in law proceeds, duly

founded and motivated, this within the term

of four months provided for in the second

paragraph of article 52 of the legal

instrument mentioned in the first term.

07

MGO100409585

MRCI DEL GOLFO, S.A.

DE C.V.

Nullity Trial 21/

488-24-01-01-01-OL

01 of December

of 2022

Specialized

Chamber

Mixed in Online Trials

and in Matters

Environmental and of

Regulation of the

Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution 600-44-00-00-00- 2021-0132 of date 18 of January of 2021,

issued by the

Concentrated Legal Administration of Oaxaca "1",

by means of which, the

Administrative Recourse of Revocation Online

RRL2020009809 was resolved, as well as,

the originally appealed 500-44-00-00-00- 2020-08420 of 24 of September of 2020,

signed by the

Concentrated Administration of Fiscal Audit of

Oaxaca "1" is declared.

08

OOSF730812NA0

OSORIO SANTIAGO

FORTINO

Nullity Trial

26396/21-17-08-8

26 of May

of

2023

Eighth Regional

Metropolitan Chamber

of the Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution is declared

500-71-06-01-03-2020-64230

of date March 10, 2021, issued

by the Concentrated Administration of

Fiscal Audit of the Federal District "1",

for effect that the authority issues a

new resolution duly founded and

motivated [ ... ] and proceeds to publish in the

Official Gazette of the Federation and in the

Internet page of the Service of

Tax Administration, in the list

corresponding [ ... ].

09

QAE160811830

QARR ARRENDADORA

DE EQUIPOS,

S.A. DE

C.V.

Nullity Trial

15792/20-17-07-9

10 of November

of 2023

Seventh Regional

Metropolitan Chamber

of the Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution is declared

600-74-00-02-00-2020-4375

of date June 29, 2020, issued by

the Concentrated Legal Administration

of the Federal District "4", by means of which

the Administrative Recourse of Revocation Online

RRL2020003402 was resolved,

as well as, the originally appealed

500-74-05-04-01-2020-10911 of 05 of

March of 2020, signed by the

Concentrated Administration of

Fiscal Audit of the Federal District "4" is declared.

10

TCT140331PXA

TECNO CUEROS Y

TANINOS CUPRA,

S.A.

DE C.V.

Nullity Trial

510/24-30-01-4-OT

13 of June

of

2024

Regional Chamber

of the Center IV of the

Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution is declared

500-25-00-05-01-2024-4325

of date February 23, 2024, issued

by the Concentrated Administration of

Fiscal Audit of Guanajuato " 2 " , for the

effect that the defendant authority performs

the corresponding management to ensure that the plaintiff is included in the list that

corresponds.

11

YAS151027P52

YESHER ASESORES,

S.A. DE C.V.

Nullity Trial

23610/20-17-06-1

03 of November

of 2021

Sixth Regional

Metropolitan Chamber

of the Federal Tribunal of

Administrative Justice

The nullity of the impugned resolution 500-05-2020-23510

of date 16 of October of 2020, issued

by the Central Administration of

Strategic Auditing is declared.

By virtue of the above, it is informed that, as a consequence of the means of defense indicated

in the preceding paragraph, the procedure of Article 69-B of the Fiscal Code of the Federation, followed to

those taxpayers, has been left without effect.

Finally, it is informed that the fact that the aforementioned taxpayers

have obtained a

favorable resolution against the presumption notice and/or definitive resolution, does not exempt them from

the responsibility they may have regarding other fiscal receipts that they issued without having the

assets, personnel, infrastructure or material capacity, directly or indirectly, to provide the services or

produce, commercialize or deliver the goods that backed such receipts, for which reason, the faculties of the

tax authority are reserved.

Respectfully.

Mexico City, November 11, 2024. - In supplement for absence of the Central Administrator of

Strategic Auditing, of the Coordinator of Strategic Auditing, of the Administrator of Strategic

Auditing " 1 " , " 2 " , " 3 " , " 4 " , " 5 " and " 6 " , based on articles 4, fourth paragraph, and 22, last paragraph,

numeral 5 subsection h), of the Internal Regulations of the Tax Administration Service in force, signs: C.P.

Nayeli Margarita Ramos Hernández , Administrator of Strategic Auditing " 7 " . - Rubric.

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