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

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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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