When Postal Receipts Lead to the Revocation of a Tax Assessment

A taxpayer who had not filed an income tax return was subject to an audit of his personal tax situation. Following the audit,administration a reassessment proposal June 13, 2017, which he claims never to have received.

The tax assessment was thus challenged all the way up to the Administrative Court of Appeals.

administration , which had not received an acknowledgment of receipt for the mailed letter, then submitted to the Court a certificate dated September 30, 2017, from the postal service’s customer service department stating that the envelope containing the reassessment proposal indeed been delivered on June 16, 2017. Since the letter was not claimed thereafter, it was returned toadministration July 4.

The taxpayer, for his part, provided a statement from the postal service’s operations department indicating that, due to a delivery error, the letter had never been delivered to his home.

He also provided other documentation showing that the delivery notice could not be placed in his mailbox due to an "address unknown" issue.

The court will then rule that even though these certificates were issued several years after the reassessment proposal was sent, they "were issued by the authorities responsible for mail delivery and contain precise and consistent information."

The court therefore ruled thatadministration prove that the notice of the reassessment proposal had been properly served reassessment proposal set aside the reassessment.

CAA Toulouse, Oct. 2, 2025, No. 23TL02303

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