2026-04-30 | DOF 5786350Added · Updated
The Tax Administration Service communicates that the tax procedures under Article 69-B of the Federal Tax Code (effective until July 24, 2018) against DIPO CONSTRUCCIONES, S.A. DE C.V. and RENTERIA MORALES MARIA DE JESUS have been rendered without effect due to favorable judicial rulings declaring the nullity of the respective definitive resolutions. This notice lists the taxpayers, their tax identification numbers, the legal challenges filed, and the specific court decisions that invalidated the original tax presumptions. The authority explicitly reserves its powers to investigate other fiscal receipts issued by these entities without adequate assets, personnel, infrastructure, or material capacity.
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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
01
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
02
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
01
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
02
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
01
DCO130529RN7
DIPO CONSTRUCCIONES, S.A. DE C.V.
500-05-2018-10859 of 27 of April of 2018
21 of May of 2018
02
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
01
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.
02
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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