Whenadministration to disregard an acknowledgment of receipt because a lawyer is involved in numerous cases in which the government has lost correspondence

Some taxpayers were subject to a tax assessment that was challenged in court.

A hearing was then held before the Administrative Court of Appeals regarding the validity of the procedure, and in particular the fact thatadministration granted the taxpayer a meeting with the supervisor.

The taxpayers, through their attorney, argued that two appeals had been sent toadministration by certified mail—one in 2019 and another in 2020.

In order to dispute the receipt of the second letter,administration that the supporting documents submitted by the taxpayers be excluded from the proceedings,"particularly in light of the large number of cases involving [their attorney] in which critical correspondence was allegedly lost byadministration ."

The Administrative Court of Appeals will note, however, that the taxpayers submitted a return receipt bearing the same registered mail tracking number as the letter itself.

She also notes that "none of the documents in the record support theadministration allegations regarding the lack of authenticity of this document, the original of which was added to the record following a request to that effect by the court."

The adjustment for the year in which the guarantee was not met is therefore canceled.

CAA Paris, May 5, 2026, No. 24PA04064

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