RegAlertNews · SHCP · 3 Oct 2025 · DOF 5769104
Notice 500-05-2025-20451 Communicating List of Taxpayers Who Challenged Presumption Notices or Resolutions Under Article 69-B of the Federal Tax Code and Obtained Annulment
The Central Administration of Strategic Auditing communicates that the tax procedures under Article 69-B of the Federal Tax Code against eleven specific taxpayers have been rendered without effect following judicial annulments of the original presumption notices or definitive resolutions. The affected taxpayers are Comercializadora Avelino, S.A. de C.V., Central Logistic Medios, S.A. de C.V., Duran Robles Luis, Futbol Salud y Cultura, S.A. de C.V., In Business by Q and A, S.A. de C.V., Lonnings Services, S.A. de C.V., Medical & Technical Books, S.A. de C.V., O-Neconst, S.A. de C.V., Parolla Consulting, S.A. de C.V., Proyectos Desarrollo Comunidad y Medio Ambiente, S.C., and Servicios y Asesoria Manlla, S.A. de C.V. The notice clarifies that this annulment does not exempt these entities from liability regarding other fiscal receipts issued without the necessary assets, personnel, infrastructure, or material capacity, thereby preserving the tax authority's powers.
DOF: 03/10/2025
OFFICE 500-05-2025-20451 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 seal with the National Coat of Arms, which says: United Mexican States.- Treasury.- Ministry of
Treasury and Public Credit.- Tax Administration Service.- General Administration of Federal Fiscal Auditing
Central Administration of Strategic Auditing.
OFFICE: 500-05-2025-20451
Subject: Communication of the list of taxpayers who
promoted some means of defense against the
presumption notice referred to in Article 69-B
first paragraph of the CFF or against the resolution
referred to in the fourth paragraph of the article in
question, and once resolved, the body
jurisdictional or administrative left without effect the
referred act.
This Central Administration of Strategic Auditing, attached to the General Administration of Federal Fiscal Auditing, 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
december 15, 1995, amended 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 to 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 accordance with what is established in the first paragraph of the First Transitory Article of said Regulations, and
amended by Decree by which various provisions of the Internal Regulations
of the Ministry of Treasury and Public Credit and of the Internal Regulations of the Service
of Tax Administration, and by which the Internal Regulations of the National Agency of Customs are issued
of Mexico, published in the same official organ on December 21, 2021, in force from January 01,
2022, in accordance with what is established in the First Transitory Article of said Decree; Third Article,
fraction I, subsection a), of the Agreement by which various attributions are delegated to Public Servants
of the Tax Administration Service, published in the Official Gazette of the Federation on June 23 of
2016, in force from July 23, 2016, in accordance with what is established in the Transitory Article
First of said Agreement; in articles 33, last paragraph, 63 and 69-B, sixth paragraph of the Fiscal Code of the
Federación, communicates the following:
That to the taxpayers listed below, at some point, they were notified of an Office of
Presumption of non-existence of operations backed by certain fiscal receipts that
they issued, this in accordance with the first and second paragraphs of article 69-B of the Fiscal Code of the
Federación, in relation to article 69 of its Regulations.
Following the procedure provided for in the aforementioned article 69-B of the Fiscal Code of the Federación, and in
terms of the fourth paragraph of the aforementioned article, the taxpayers in reference 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
social reason of the
Taxpayer
Number and date
of office of
definitive resolution
Means of notification to the taxpayer
Authority's public notice
Personal Notification
Tax Box
Date of posting
on the public notice
of the Fiscal
Authority
Date on which
the notification
took effect
Date of
notification
Date on which
the notification
took effect
Date of
notification
Date on which
the notification
took effect
01
CAV150603G34
COMERCIALIZADORA
AVELINO, S.A. DE C.V.
500-05-2023-
21089 dated August 23
2023
August 29
2023
August 30, 2023
02
CLM131105QP1
CENTRAL LOGISTIC
MEDIOS, S.A. DE C.V.
500-44-00-00-00-
2020-00461 of
dated January 20
2020
February 13, 2020
March 09, 2020
03
DURL861015SV2
DURAN ROBLES LUIS
500-04-00-00-00-
2021-16527 of
dated May 20
2021
May 26, 2021
June 07, 2021
04
FSC1405128C0
FUTBOL, SALUD Y
CULTURE, S.A. DE C.V.
500-31-00-06-04-
2019-1795 of
dated August 02
2019
August 08
2019
August 09, 2019
05
IBB120719PC6
IN BUSINESS BY Q AND
A, S.A. DE C.V.
500-57-00-04-01-
2019-005791 of
dated December 17
2019
January 08
2020
January 09, 2020
06
LSE160825DH8
LONNINGS SERVICES,
S.A. DE C.V.
500-05-2021-4990
dated January 28
2021
January 28
2021
January 29, 2021
07
MAT0903184TA
MEDICAL & TECHNICAL
BOOKS, S.A. DE C.V.
500-46-00-05-02-
2020-4151 of
dated January 21
2020
January 22
2020
January 23, 2020
08
ONE121202FA7
O-NECONST, S.A. DE C.V.
500-44-00-00-00-
2018-12417 of December 18
2018
January 07
2019
January 08, 2019
09
PCO1608257Z5
PAROLLA CONSULTING,
S.A. DE C.V.
500-05-2020-
28755 dated December 02
2020
December 02
2020
December 03, 2020
10
PDC130201618
PROJECTS,
DEVELOPMENT,
COMMUNITY AND ENVIRONMENT
AMBIENT, S.C.
500-39-00-04-01-
2019-3187 of
dated March 28
2019
March 28
2019
March 29, 2019
11
SAM150421F58
SERVICES AND ADVISORY
MANLLA, S.A. DE C.V.
500-18-00-05-02-
2021-2515 of
dated May 18
2021
May 19
2021
May 20, 2021
Additional data of taxpayers.
No.
R.F.C.
Name, denomination or social
reason of the Taxpayer
Fiscal Address
Preponderant Activity
Reason for the Procedure
01
CAV150603G34
COMERCIALIZADORA AVELINO, S.A.
DE C.V.
Miguel Hidalgo Borough, Mexico
city
Other wholesale trade intermediaries
Absence of assets
Absence of
personnel
Lack of infrastructure
02
CLM131105QP1
CENTRAL LOGISTIC MEDIOS, S.A.
DE C.V.
Oaxaca de Juárez, Oaxaca
Other advertising services
Absence of asset
Absence of
personnel
03
DURL861015SV2
DURAN ROBLES LUIS
Chihuahua, Chihuahua
Wholesale trade of metallic waste
Absence of assets
Absence of
personnel
Lack of infrastructure
No
material capacity
04
FSC1405128C0
FUTBOL, SALUD Y CULTURE, S.A.
DE C.V.
Guadalajara, Jalisco
Other scientific and technical consulting services
Absence of asset
Absence of
personnel
05
IBB120719PC6
IN BUSINESS BY Q AND A, S.A.
DE C.V.
Villahermosa, Tabasco
Computer consulting services
Absence of assets
Absence of
personnel
No material capacity
06
LSE160825DH8
LONNINGS SERVICES, S.A. DE C.V.
Miguel Hidalgo Borough, Mexico
city
Research and protection and
custody services, except by monitoring
Absence of asset
Absence of
personnel
07
MAT0903184TA
MEDICAL & TECHNICAL BOOKS, S.A.
DE C.V.
Heroic Puebla de Zaragoza,
Puebla
Wholesale trade of books
Absence of assets
Absence of
personnel
No material capacity
08
ONE121202FA7
O-NECONST, S.A. DE C.V.
Villa Guerrero, State of Mexico
Other specialized work for the
construction
Absence of asset
Absence of
personnel
09
PCO1608257Z5
PAROLLA CONSULTING, S.A. DE C.V.
Naucalpan de Juárez Municipality,
State of Mexico
Other professional, scientific and
technical services
Absence of asset
Absence of
personnel
10
PDC130201618
PROJECTS, DEVELOPMENT,
COMMUNITY AND ENVIRONMENT
AMBIENT,
S.C.
Jiutepec, Morelos
Other professional, scientific and
technical services
Absence of asset
Absence of
personnel
11
SAM150421F58
SERVICES AND ADVISORY MANLLA,
S.A. DE C.V.
Toluca, State of Mexico
Accounting and auditing service
Absence of personnel
Lack of
infrastructure
No material
capacity
For the above reason, the name or social reason 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 Federación, which was published in the Official Gazette of the Federation, as indicated below:
No.
R.F.C.
Name, denomination or social reason of the
Taxpayer
Number and date of office containing in Global List
Definitive
Date of publication in the Official
Gazette of the Federation
01
CAV150603G34
COMERCIALIZADORA AVELINO, S.A. DE C.V.
500-05-2023-26217 dated December 11, 2023
February 02, 2024
02
CLM131105QP1
CENTRAL LOGISTIC MEDIOS, S.A. DE C.V.
500-05-2020-13598 dated May 21, 2020
June 24, 2020
03
DURL861015SV2
DURAN ROBLES LUIS
500-05-2021-25924 dated August 16, 2021
September 27, 2021
04
FSC1405128C0
FUTBOL, SALUD Y CULTURE, S.A. DE C.V.
500-05-2019-35911 dated October 25, 2019
November 20, 2019
05
IBB120719PC6
IN BUSINESS BY Q AND A, S.A. DE C.V.
500-05-2020-7897 dated March 18, 2020
April 16, 2020
06
LSE160825DH8
LONNINGS SERVICES, S.A. DE C.V.
500-05-2021-10803 dated March 25, 2021
April 08, 2021
07
MAT0903184TA
MEDICAL & TECHNICAL BOOKS, S.A. DE C.V.
500-05-2020-13709 dated June 25, 2020
July 08, 2020
08
ONE121202FA7
O-NECONST, S.A. DE C.V.
500-05-2019-7298 dated February 25, 2019
April 03, 2019
09
PCO1608257Z5
PAROLLA CONSULTING, S.A. DE C.V.
500-05-2021-5303 dated March 04, 2021
March 18, 2021
10
PDC130201618
PROJECTS, DEVELOPMENT, COMMUNITY AND ENVIRONMENT
AMBIENT, S.C.
500-05-2019-18069 dated May 24, 2019
June 28, 2019
11
SAM150421F58
SERVICES AND ADVISORY MANLLA, S.A. DE C.V.
500-05-2021-26283 dated December 07, 2021
January 12, 2022
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
social reason 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
CAV150603G34
COMERCIALIZADORA
AVELINO, S.A. DE C.V.
Nullity Trial 23295/
23-17-12-1
December 03
2024
Twelfth Regional Metropolitan Chamber of the
Federal Court of Administrative Justice
The nullity of the challenged resolution 500-05-2023-21089 of
August 23, 2023, issued by the
Central Administration of Strategic Auditing is declared.
02
CLM131105QP1
CENTRAL LOGISTIC
MEDIOS, S.A. DE C.V.
Nullity Trial 1796/
20-15-01-5
February 16, 2023
Regional Chamber of the Southeast of the
Federal Court of Administrative Justice
The nullity of the challenged resolution 500-44-00-00-00-2020- 00461 of January 20, 2020, issued by the
Decentralized Administration of Fiscal Auditing of Oaxaca "1" is declared.
03
DURL861015SV2
DURAN ROBLES LUIS
Nullity Trial 3035/
22-04-01-3-OT
August 02, 2023
Regional Chamber of the North-
Center I of the Federal Court of
Administrative Justice
The nullity of the challenged resolution 500-04-00-00-00-2021- 16527 of May 20, 2021, issued by the
Central Administration of Verification and
Evaluation of Federal Entities in
Fiscal Coordination matters is declared.
04
FSC1405128C0
FUTBOL, SALUD Y
CULTURE, S.A. DE C.V.
Nullity Trial 3921/
20-07-03-4
November 19
2021
Third Regional Chamber of
the West of the Federal Court of
Administrative Justice
The nullity of the challenged resolution 500-31-00-06-04-2019- 1795 of August 02, 2019, issued by the
Decentralized Administration of Fiscal Auditing
of Jalisco "2" is declared.
05
IBB120719PC6
IN BUSINESS BY Q AND A,
S.A. DE C.V.
Nullity Trial 611/20-
26-01-3
March 04, 2025
Regional Chamber of Tabasco and
Auxiliary of the Federal Court of
Administrative Justice
The nullity of the challenged resolution is declared
600-57-04-2020-0714 of June 11,
2020, issued by the Administration
Decentralized Legal of Tabasco "1", which
resolved the Online Administrative Revocation Appeal, as well as,
the originally appealed 500-57-00-04-01-2019- 005791 dated December 17, 2019,
signed by the Decentralized Administration
of Fiscal Auditing of Tabasco "1".
06
LSE160825DH8
LONNINGS SERVICES, S.A.
DE C.V.
Nullity Trial 1199/
21-02-01-4
November 16
2023
Regional Chamber of the Northwest II
of the Federal Court of
Administrative Justice
The nullity of the fictitious denial of the Online Administrative Revocation Appeal RRL2021003129 is declared,
promoted before the Administration
Decentralized Legal of the Federal District
"1", as well as the originally appealed
500-05-2021-4990 dated January 28, 2021, signed by the Central Administration of
Strategic Auditing.
07
MAT0903184TA
MEDICAL & TECHNICAL
BOOKS, S.A. DE C.V.
Nullity Trial 20/
1373-24-01-01-07-OL
April 11, 2024
Specialized Mixed Chamber in
Online Trials and in Matters
Environmental and Regulatory of the
Federal Court of Administrative
Justice
The nullity of the challenged resolution is declared
600-45-00-04-00-2020-2018 of June 01
2020, issued by the Administration
Decentralized Legal of Puebla "1", which
resolved the Online Administrative Revocation Appeal RRL2020001853, as
well as, the originally appealed 500-46-00- 05-02-2020-4151 of January 21, 2020,
signed by the Decentralized Administration
of Fiscal Auditing of Puebla "2".
08
ONE121202FA7
O-NECONST, S.A. DE C.V.
Nullity Trial 798/19-
15-01-8
April 14, 2023
Regional Chamber of the Southeast of the Federal Court of
Administrative Justice
The nullity of the challenged resolution is declared
500-44-00-00-00-2018-12417 of
December 18, 2018, issued by the
Decentralized Administration of Fiscal Auditing
of Oaxaca "1".
09
PCO1608257Z5
PAROLLA CONSULTING,
S.A. DE C.V.
Nullity Trial 1009/
21-02-01-5
December 02
2022
Regional Chamber of the Northwest II
of the Federal Court of
Administrative Justice
The nullity of the fictitious confirmative of the Online Administrative Revocation Appeal is declared
RRL2021003129, promoted before the
Decentralized Legal Administration of
Mexico "2", as well as the originally
appealed 500-05-2020-28755 of December 02
2020, signed by the
Central Administration of Strategic Auditing.
10
PDC130201618
PROJECTS,
DEVELOPMENT,
COMMUNITY AND ENVIRONMENT
AMBIENT, S.C.
Nullity Trial 245/20-
24-01-6
August 21, 2023
Regional Chamber of Morelos of the
Federal Court of Administrative
Justice
The nullity of the challenged resolution is declared
600-39-00-02-00-2020-425 of January 29
2020, issued by the
Decentralized Legal Administration of
Morelos "1", which resolved the Online Administrative Revocation Appeal
RRL2019004059, as well as, the
originally appealed 500-39-00-04-01-2019- 3187 of March 28, 2018, issued by the
Decentralized Administration of Fiscal Auditing
of Morelos "1".
11
SAM150421F58
SERVICES AND ADVISORY
MANLLA, S.A. DE C.V.
Nullity Trial 0044-
2021-02-C-15-04-02-01-L
June 21, 2024
Regional Chamber South of the State
of Mexico and Auxiliary of the
Federal Court of Administrative
Justice
The nullity of the challenged resolution is declared
600-18-2021-1286 of August 24
2021, issued by the Administration
Decentralized Legal of Colima "1", which
resolved the Online Administrative Revocation Appeal RRL2021007885, as
well as, the originally appealed 500-18-00- 05-02-2021-2515 of May 18, 2021,
signed by the Decentralized Administration
of Fiscal Auditing of Colima "1".
In view of the above, it is communicated that, as a consequence of the means of defense indicated
in preceding paragraphs, the procedure of article 69-B of the Fiscal Code of the Federación, followed to
those taxpayers, has become 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 they have 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, the powers of the tax authority are reserved.
Sincerely.
Mexico City, August 12, 2025. - Central Administrator of Strategic Auditing, L.C.
Rubén Martín López Rodríguez .- Rubric.
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- Internal Regulations of the Tax Administration Service, published in the Official Gazette of the Federation on August 24, 2015Not in RegAlert
“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”
- of 2016Not in RegAlert
“Third Article, fraction I, subsection a), of the Agreement by which various attributions are delegated to Public Servants of the Tax Administration Service”
- Regulation of 2021Not in RegAlert
“amended by Decree by which various provisions of the Internal Regulations of the Ministry of Treasury and Public Credit and of the Internal Regulations of the Service of Tax Administration”
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