Decision by the Bordeaux Administrative Court of Appeal regarding the lack of sufficient reasoning in the response to the taxpayer’s comments
administration had adjusted a taxpayer’s tax assessment upward, concluding that the value of the shares in a limited liability company (SELARL) that owned a pharmacy had been undervalued.
The taxpayer had submitted comments on the reassessment proposal which he outlined the methods used to value the securities.
In its response to these comments,administration address those concerning a valuation method used by the taxpayer.
The Administrative Court of Appeals finds that the proceeding is invalid because the response to the briefs was insufficiently reasoned.