Can a discrepancy in an inspector’s signature invalidate a tax assessment?

A certified public accountant who had been subject to a tax audit was notified of an assessment that included a 40% penalty for willful misconduct.

Since the imposition of this penalty required the signature of an inspector holding at least the rank of divisional inspector, he attempted to argue that this condition had not been met.

The taxpayer believed that there was a discrepancy between the signature of the divisional inspector on the reassessment proposal the one on the response to the taxpayer’s comments, making it impossible to be certain that the documents had been signed by the same person.

The Administrative Court of Appeal, to which the case was referred, will, however, rule that "an examination of the disputed documents does not reveal that the signatures appearing therein—which cannot be strictly identical since they are handwritten—exhibit such marked variations in handwriting that it would be possible to conclude that they were clearly not all affixed by the senior inspector whose name is mentioned."

The Court thus upholds the imposition of the penalties and rejects the taxpayer's argument.

Based on a line of reasoning by way of contradiction—which always has its limitations—this would suggest that very different signatures could have led to the cancellation of the tax assessments.

CAA Paris, Jan. 8, 2026, No. 25PA01006

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.