Notice 500-05-2026-11154 Communicating List of Taxpayers Who Filed Legal Challenges Against Presumption Notices Under Article 69-B of the Federal Tax Code — SHCP — MX

DOF: 30/04/2026

OFFICE 500-05-2026-11154 through which a 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 judicial or administrative body left the referred act unsubstantiated, is communicated.

A seal with the National Emblem is placed at the margin, 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 Auditing.

OFFICE: 500-05-2026-11154

Subject:

A 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 judicial or administrative body left the referred act unsubstantiated, is communicated.

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 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 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, 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 Eighth Transitory Article, fraction IV, of the Fiscal Miscellany Resolution for 2026, published in the Official Gazette of the Federation on December 28, 2025, communicates the following:

That to the taxpayers listed below, a Presumption Notice of non-existence of operations backed by certain fiscal receipts issued by them was notified at the time, 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 taxpayers of reference 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 Stands

Personal Notification

Tax Box

Date of fixation

on the stands

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

DCO130529RN7

DIPO CONSTRUCCIONES,

S.A. DE C.V.

500-67-00-05-03-

2018-2066 of 08

of February 2018

15 of February of

2018

16 of February of

2018

REMJ870807LU5

RENTERIA MORALES MARIA

DE JESUS

500-21-00-04-02-

2018-3502 of 19

of September of

2018

02 of October of

2018

03 of October of

2018

Additional data of the taxpayers.

No.

R.F.C.

Name, denomination or social reason of the

Taxpayer

Fiscal Address

Preponderant Activity

Reason for the Procedure

DCO130529RN7

DIPO CONSTRUCCIONES, S.A. DE C.V.

Coatzacoalcos, Veracruz

Other civil engineering constructions or heavy work

Absence of Assets

Absence of

Personnel

Lack of Infrastructure

Without

Material Capacity

REMJ870807LU5

RENTERIA MORALES MARIA DE JESUS

Chihuahua, Chihuahua

Other installations and equipment in

constructions

Absence of Assets

Absence of

Personnel

For the above, the name or social reason 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.

R.F.C.

Name, denomination or social reason of the Taxpayer

Number and date of office that contains in Global List

Definitive

Date of publication in the

Official Gazette of the

Federation

DCO130529RN7

DIPO CONSTRUCCIONES, S.A. DE C.V.

500-05-2018-10859 of 27 of April of 2018

21 of May of 2018

REMJ870807LU5

RENTERIA MORALES MARIA DE JESUS

500-05-2018-32756 of 28 of November of 2018

13 of January of 2019

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

No.

R.F.C.

Name, denomination or social

reason of the Taxpayer

Means of defense

Date of the

Resolution or

firm sentence

Authority that resolved

Sense and/or effect of the resolution

or firm sentence

DCO130529RN7

DIPO CONSTRUCCIONES, S.A.

DE C.V.

Nullity Trial

358/21-13-01-9

17 of August of 2023

First Regional Chamber of the Gulf

of the Federal Tribunal of Administrative

Justice

The nullity of the impugned resolution 500-67-00-

05-03-2018-2066 of 08 of February of 2018, issued by the

Decentralized Administration of Fiscal Audit of

Veracruz "4" is declared.

REMJ870807LU5

RENTERIA MORALES MARIA DE

JESUS

Nullity Trial

0119-2023-02-C-08-

01-03-02-L

02 of May of 2024

Regional Chamber of the North-Center I

of the Federal Tribunal of Administrative

Justice

The nullity of the impugned resolution

500-21-00-04-02-2018-3502 of 19 of September of 2018,

issued by the Decentralized Administration of Fiscal Audit

of Chihuahua "1" is declared plain and simple.

In view of the above, it is communicated that, as a consequence of the means of defense indicated in the paragraph

that precedes, the procedures of Article 69-B of the Federal Tax Code valid until July 24, 2018,

followed against those taxpayers, have become without effect.

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

have obtained a favorable resolution in

against the presumption notice and/or definitive resolution, does not exempt them from the responsibility they may have regarding other

fiscal receipts that 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 reason, the powers of the fiscal authority are reserved.

Respectfully.

Mexico City, February 20, 2026.- Central Administrator of Strategic Auditing, L.C. Rubén Martín

López Rodríguez .- Rubric.

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