Notice 500-05-2025-5869 Communicating List of Taxpayers Who Challenged Presumption Notices Under Article 69-B of the Federal Tax Code Valid Until July 24, 2018

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DOF: 04/04/2025

OFFICE 500-05-2025-5869 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, valid until July 24, 2018, or against the resolution referred to in the third paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act unsubstantiated.

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 Fiscalization.

OFFICE: 500-05-2025-5869

Subject: Communication of 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 (CFF), valid until July 24, 2018, or against the resolution referred to in the third paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act unsubstantiated.

This Central Administration of Strategic Fiscalization, 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 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, effective 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, effective from January 1, 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, effective from July 23, 2016, in accordance with what is established in the First Transitory Article of said Agreement; in articles 33, last paragraph, 63 and 69-B, first and second paragraphs of the Federal Tax Code valid until July 24, 2018, in relation to the Second Transitory Article of the "DECREE by which Article 69-B of the Federal Tax Code is reformed", published in the Official Gazette of the Federation on June 25, 2018 and Article Eighth Transitory, fraction IV, of the Fiscal Miscellany Resolution for 2025, published in the Official Gazette of the Federation on December 30, 2024, communicates the following to you:

That to the taxpayers listed below, at the time, a Notice of Presumption of non-existence of operations backed by certain fiscal receipts issued by them was notified, this in accordance with the first and second paragraphs of article 69-B of the Federal Tax Code, valid until July 24, 2018, in relation to article 69 of its Regulations.

Following the procedure provided for in the aforementioned article 69-B of the Federal Tax Code, valid until July 24, 2018, and in terms of the third paragraph of the mentioned article, the definitive resolution was notified to the reference taxpayers as indicated below:

Notification to taxpayers of the OFFICE OF THE DEFINITIVE RESOLUTION.

No.

RFC

Name, denomination or corporate name of the Taxpayer

Number and date of the definitive resolution office

Means of notification to the taxpayer

Authority's Court

Personal Notification

Tax Box

Date of posting

on the Authority's Court

Date on which

notification took effect

Date of

notification

Date on which

notification took effect

Date on

which it was

notified in

Tax Box

Date on which

notification took effect

01

CCG1110042T0

COMERCIALIZADORA Y

CONSTRUCTORA GORA, S.A. DE

C.V.

500-05-2017-32033 dated

August 21

2017

September 08

2017

October 06

2017

02

PECY670525PN5

PEREZ CAZARES YOLANDA

500-05-2015-30989 dated

August 24

2015

February 11, 2016

March 07, 2016

03

RBC110622K85

RODAVOF BCS, S.A. DE C.V.

500-13-00-02-00-2017-6006 dated December 14

2017

December 15

2017

December 18

2017

04

SOLF691221NH0

SOTO LARRONDO FRANCISCO

JOSE

500-47-00-07-02-2018-002514 dated

June 15, 2018

June 25

2018

August 01

2018

05

VIVP810703PI4

VILLARREAL VILLARREAL PAOLA

BERENICE

500-15-05-01-2017-0182 dated March 14

2017

March 28, 2017

April 24, 2017

Additional data of the taxpayers.

No.

RFC

Name, denomination or corporate name

of the Taxpayer

Fiscal Address

Preponderant Activity

Reason for the Procedure

01

CCG1110042T0

COMERCIALIZADORA Y

CONSTRUCTORA GORA,

S.A. DE C.V.

BOCA DEL RÍO, VERACRUZ

DE IGNACIO DE LA LLAVE

WHOLESALE TRADE OF DAIRY PRODUCTS,

AS CREAM, BUTTER, YOGURT,

CHEESE

Absence of assets

Absence

of personnel

02

PECY670525PN5

PEREZ CAZARES YOLANDA

TONALÁ, JALISCO

WHOLESALE TRADE OF METAL MATERIALS

Absence of assets

Absence

of personnel

Lack of

infrastructure

No material

capacity

03

RBC110622K85

RODAVOF BCS, S.A. DE C.V.

LOS CABOS, BAJA

CALIFORNIA SUR

MARKET RESEARCH SERVICES

AND PUBLIC OPINION SURVEYS

Absence of assets

Absence

of personnel

Lack of

infrastructure

No material

capacity

04

SOLF691221NH0

SOTO LARRONDO FRANCISCO JOSE

EL MARQUÉS, QUERÉTARO

CONSTRUCTION OF COMMERCIAL,

INSTITUTIONAL

AND SERVICE PROPERTIES

Absence of assets

Absence

of personnel

05

VIVP810703PI4

VILLARREAL VILLARREAL PAOLA

BERENICE

MONCLOVA, COAHUILA DE

ZARAGOZA

OTHER EDUCATIONAL SERVICES

PROVIDED BY THE

PRIVATE SECTOR

Absence of assets

Absence

of personnel

Therefore, the name or corporate name of the taxpayers

to whom the aforementioned resolutions were notified, were added to the

list referred to in the third paragraph of Article 69-B of the Federal Tax Code, valid until July 24, 2018, which

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

No.

RFC

Name, denomination or corporate name

of the

Taxpayer

Number and date of the office containing in

Definitive Global List

Date of publication

in the

Official Gazette

of the Federation

01

CCG1110042T0

COMERCIALIZADORA Y CONSTRUCTORA GORA,

S.A. DE C.V.

500-05-2017-38731 dated November 27, 2017

December 14, 2017

02

PECY670525PN5

PEREZ CAZARES YOLANDA

500-05-2016-21473 dated June 23, 2016

July 18, 2016

03

RBC110622K85

RODAVOF BCS, S.A. DE C.V.

500-05-2019-27684 dated August 14, 2019

September 05, 2019

04

SOLF691221NH0

SOTO LARRONDO FRANCISCO JOSE

500-05-2018-32782 dated December 12, 2018

January 14, 2019

05

VIVP810703PI4

VILLARREAL VILLARREAL PAOLA BERENICE

500-05-2017-16355 dated July 14, 2017

August 16, 2017

Unhappy with the individual presumption office or definitive resolution office, they filed means of defense, which were concluded with the following resolution or sentence:

No.

RFC

Name, denomination or

corporate 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

CCG1110042T0

COMERCIALIZADORA Y

CONSTRUCTORA GORA, S.A.

DE C.V.

Nullity Trial 18/

2296-24-01-02-02-OL

November 03, 2023

Specialized Mixed Chamber in

Online Trials and in Environmental

and Regulatory Matters of the

Federal Tribunal of Fiscal

and Administrative Justice

The nullity of the challenged resolution is declared

500-05-2017-32033 dated August 21

2017, issued by the

Central Administration of Strategic Fiscalization.

02

PECY670525PN5

PEREZ CAZARES YOLANDA

Nullity Trial 28639/

22-17-06-6

May 17

2024

Sixth Metropolitan Regional Chamber

of the Federal Tribunal of

Administrative Justice

The nullity of the challenged resolution is declared

500-05-2015-30989 dated August 24

2015, issued by the

Central Administration of Strategic Fiscalization.

03

RBC110622K85

RODAVOF BCS,

S.A. DE C.V.

Nullity Trial 4791/

18-03-01-10

March 01

2023

First Regional Chamber of the

Northwest III of the Federal Tribunal

of Administrative Justice

The plain and simple nullity of the

challenged resolution is declared, ficta negative received

to the Online Administrative Revocation Recourse

RRL2018001437, as well as of the

originally challenged 500-13-00-02-00- 2017-6006 of December 14, 2017,

signed by the Decentralized Administration

of Fiscal Audit of Baja California Sur "2".

04

SOLF691221NH0

SOTO LARRONDO

FRANCISCO JOSE

Nullity Trial 1464/

22-09-01-8-OT

August 03

2023

Regional Chamber of the Center II of the

Federal Tribunal of Justice

Administrative

The nullity of the challenged resolution is declared

500-47-00-07-02-2018-002514 of

June 15, 2018, issued by the

Decentralized Administration of Fiscal

Audit of Querétaro "1".

05

VIVP810703PI4

VILLARREAL VILLARREAL

PAOLA BERENICE

Nullity Trial 3241/

18-05-01-9

June 07

2023

First Regional Chamber North

Center II of the Federal Tribunal of

Administrative Justice

The plain and simple nullity of the

challenged resolution is declared

600-15-2018-1835 of

June 29, 2018, issued by the

Decentralized Juridical Administration of

Coahuila de Zaragoza "1", by means of which

the online revocation recourse was dismissed

RRL2017011652, as well as of the

originally challenged 500-15-05-01-2017- 0182 dated March 14, 2017, signed

by the Decentralized Administration of

Fiscal Audit of Coahuila de Zaragoza "1".

In view of the above, it is informed that, as a consequence of the means of defense indicated in preceding paragraphs, the

procedure of Article 69-B of the Federal Tax Code valid until July 24, 2018, followed against 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 office 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, February 11, 2025. - In substitution for the absence of the Central Administrator of Strategic Fiscalization, of the

Coordinator of Strategic Fiscalization, of the Administrator of Strategic Fiscalization "1", "2", "3", "4", "5" and "6", based on the

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 Fiscalization "7". - Rubric.

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