2026-03-06 | DOF 5781640Added · Updated
The Tax Administration Service publishes a list of taxpayers who successfully disproved the presumption of non-existent operations regarding specific fiscal receipts. The document details two entities, Comercializadora Euler, S. de R.L. de C.V. and Promotora Vizquel, S.A. de C.V., noting that their inclusion in the list is limited strictly to the operations identified in the respective presumption and definitive resolution notices. The publication is issued in compliance with final court rulings declaring the nullity of previous administrative resolutions against these taxpayers.
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DOF: 06/03/2026
OFFICE 500-05-2025-36130 through which a list of taxpayers who disproved the presumption of non-existence of operations provided for in the first paragraph of Article 69-B of the Federal Fiscal Code is communicated
At the margin, a seal with the National Coat of Arms, which says: United Mexican States.- Treasury.- Ministry of Finance and Public Credit.- Tax Administration Service.- General Administration of Federal Fiscal Audit.- Central Administration of Strategic Audit.
OFFICE: 500-05-2025-36130
Subject:
A list of taxpayers who DISPROVED
the presumption of non-existence of operations provided for in the
first paragraph of Article 69-B of the Federal Fiscal Code is communicated.
This Central Administration of Strategic Audit, attached to the General Administration of Federal Fiscal Audit, of the Tax Administration Service, based on what is established in 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 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 reformed by Decree by which various provisions of the Internal Regulations of the Ministry of Finance and Public Credit and of the Internal Regulations of the Tax Administration Service 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 accordance 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 accordance with what is established in the First Transitory Article of said Agreement; as well as in Articles 33, last paragraph, 63 and 69-B, sixth paragraph of the Federal Fiscal Code,
communicates the following:
That to the taxpayers listed below, at the time, 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 Federal Fiscal Code, as well as, in particular cases, a final resolution issued in terms of the fourth paragraph of the legal provision in question; however, derived from what was resolved in the defense means filed, it is determined that said legal entities disproved the presumption of non-existence, with respect specifically to the operations indicated in said notices, whose data are the following:
Section A.- Notification of the NOTICE OF PRESUMPTION in accordance with the first and second paragraphs of Article 69-B of the Federal Fiscal Code, in relation to Article 69 of its Regulations.
No.
RFC
Name, denomination
or trade name of the
Taxpayer
Number and
date of individual
notice of
presumption
Issuing Authority
of the individual
notice of
presumption
Means of notification to the taxpayer
Authority's public records
Personal Notification
Notification via Tax Box
Date of
posting on
the public records
of the
Tax 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
1
CEU130201782
COMERCIALIZADORA
EULER, S. DE R.L. DE
C.V.
500-32-00-04-
03-2019-1447
of February 07
2019
Administration
Decentralized of
Fiscal Audit of
Jalisco " 3 "
February 12, 2019
February 13, 2019
2
PVI101217G23
PROMOTORA VIZQUEL,
S.A. DE C.V.
500-41-00-
0302-2019-
3154 dated
June 17,
2019
Administration
Decentralized of
Fiscal Audit of
Nuevo León "1"
June 26, 2019
August 02, 2019
Section B.- Notification on the Internet page of the Tax Administration Service.
No.
RFC
Name, denomination or trade name of the
Taxpayer
Number and date of Global Notice of
presumption
Date of notification on the Internet page of the
Tax Administration Service
Date on which the notification
took effect
1
CEU130201782
COMERCIALIZADORA EULER, S. DE R.L. DE
C.V.
500-05-2019-7349 dated April 01, 2019
April 01, 2019
April 02, 2019
2
PVI101217G23
PROMOTORA VIZQUEL, S.A. DE C.V.
500-05-2019-27773 dated September 02
2019
September 02, 2019
September 03, 2019
Section C.- Notification in the Official Gazette of the Federation.
No.
RFC
Name, denomination or trade name of the
Taxpayer
Number and date of Global Notice of
presumption
Date of notification in the Official Gazette
of the Federation
Date on which the notification
took effect
1
CEU130201782
COMERCIALIZADORA EULER, S. DE R.L. DE C.V.
500-05-2019-7349 of
date April 01, 2019
April 26, 2019
April 29, 2019
2
PVI101217G23
PROMOTORA VIZQUEL, S.A. DE C.V.
500-05-2019-27773 dated September 02
2019
September 25, 2019
September 26, 2019
Section D.- Notification of the FINAL RESOLUTION notice.
No.
RFC
Name, denomination or
trade name of the
Taxpayer
Number and
date of
final resolution
Issuing Authority
of the
final resolution
Means of notification to the taxpayer
Authority's public records
Date on which
the notification
took effect
Date of
notification
Date on which
the notification
took effect
Date on which
the notification
took effect
Date of
notification
Date on which
the notification
took effect
1
CEU130201782
COMERCIALIZADORA
EULER, S. DE R.L. DE C.V.
In compliance with what was ordered in the final sentence of September 01, 2023, issued by the Second Regional Chamber of the West of the Federal Administrative Justice Tribunal, within the Nullity Trial 7541/22-07-02-7, by which, the plain nullity of the challenged resolution 600-32-2022- 07713 of September 14, 2022, issued by the Decentralized Legal Administration of Jalisco "3", by which, the Online Administrative Review Resources RRL2019008184 and RRL2019009750 and RRL2019009751 were resolved, as well as, the originally challenged 500-32-00-04-03-2019-5151 of August 01
2019, issued by the Decentralized Administration of Fiscal Audit of Jalisco "3", for the effect that the authority must attend the obligation imposed on it by Article 69-B, sixth paragraph of the Federal Fiscal Code, condemning to include the data of the plaintiff in the list of taxpayers who
manage to disprove the facts imputed to them, which is published quarterly.
2
PVI101217G23
PROMOTORA VIZQUEL,
S.A. DE C.V.
In compliance with what was ordered in the final sentence of July 04, 2023, issued by the Third Regional Chamber of the Northeast of the Federal Administrative Justice Tribunal, within the Nullity Trial 188/20-06-03-5-OT, by which, the plain nullity of the challenged resolution 500-41-00-03- 02-2019-3154 of June 17, 2019, issued by the Decentralized Administration of Fiscal Audit of Nuevo León "1", for the effect that the defendant authority must order the publication of the data of the plaintiff, in the list of taxpayers who have disproved the presumption of non-existence.
Section E.- Additional taxpayer data.
No.
RFC
Name, denomination or trade name of the
Taxpayer
Fiscal Address
Predominant Activity
Reason for the Procedure
1
CEU130201782
COMERCIALIZADORA EULER, S. DE R.L. DE
C.V.
Zapopan, Jalisco
Retail trade of alcoholic beverages not
classified elsewhere
Absence of assets, Absence of personnel,
Lack of infrastructure, No material capacity
2
PVI101217G23
PROMOTORA VIZQUEL, S.A. DE C.V.
Monterrey, Nuevo León
Investment advice
Absence of assets, Absence of personnel,
Lack of infrastructure,
However, it is specified that, the fact that the aforementioned taxpayers have specifically disproved the
events recorded in the notice of presumption and of final resolution that motivated their publication in the
corresponding lists, is only in relation to the fiscal receipts indicated in the presumption notices
that were notified to them at the time, being safe the faculties of the tax authority in terms of Article 69-B
of the Federal Fiscal Code in relation to the other fiscal receipts that they may have issued.
Respectfully.
Mexico City, November 24, 2025. - Central Administrator of Strategic Audit, L.C. Rubén Martín
López Rodríguez .- Rubric.
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