The notice of administrative detention may be subject of a separate appeal to the Supreme Court recently has ruled that sections together, ponenedo end, on the one hand, such a dispute to court, and on the other, balancing a moment of genuine inequality and its true harassment the taxpayer, in fact, the prevailing attitude of the date Giuruisprudenza responsible for believing the act was not challenged autotnomamente.
Eventually the Supreme Court has ruled in favor of those who, like myself, has always supported the absurdity of this interpretation.
Persobnalmente I just presented a protective action during the proceedings in the Tax Commission, in essence a kind of art 700 cpc adapted to process tax. I will keep you in informati.Sperando to please carry the maximum of the Supreme Court mentioned above.
"The notice of administrative detention under Article. 86, Presidential Decree No. 602 of 1973 with respect to an alleged creditor of the public nature of the tax may be challenged before the tax court act as functional, with a view to protecting the right of defense of the taxpayer and the principle of sound public administration, to lead to knowledge of the taxpayer, the recipient of the detention order, a particular tax claim in respect of which lies art. 100 cpc the interest of the taxpayer to a remedy for the substantive review of the legality of the tax claim. "Court United Sections of Cassation, Judgement No. 10672/2009. Massimiliano
Scaringella
lawyer the Court of Rome
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