Is an acknowledgment of receipt that is not signed by a member of a law firm valid?

A company had been subject to a tax audit, following whichadministration issued a tax assessment. The company then retained a lawyer to challenge the assessment.

The attorney then filed a formal complaint in which he stated that the company had elected to have service of process at his office.

administration had sent a rejection of this claim to the attorney by certified mail. She received a signed acknowledgment of receipt which, in her view, confirmed receipt of the rejection of the claim.

Since the company had challenged the dismissal of its claim after the deadline for filing a lawsuit had passed, it argued that the signature on the acknowledgment of receipt did not match that of the members of the law firm.

The Administrative Court of Appeals, to which the case was referred, will nevertheless rule that:

• The company did not provide any information regarding the possible identity of the signatory or the individuals who "would nevertheless have been authorized to sign such notices"

• Other acknowledgments of receipt for letters received during the company’s tax audit bore the same signature as the one on the acknowledgment of receipt.

The Court therefore finds that the rejection of the claim was properly notified and that the petition filed with the Administrative Court was indeed filed too late.

CAA Marseille, April 24, 2026, No. 25MA00739

This legal watch provided by Mispelon Avocat, a law firm specializing in French tax audit and French tax litigation. You can stay legal watch subscribing to the newsletter via this link.