Hold the notice of administrative detention!
E 'with the ruling n.11087 a few days ago that the United Sections of the Supreme Court has finally and definitively clarified hope that "... the notice of administrative detention provided for by 'art.86 of dPRn602/73, with respect to an alleged creditor of the public nature of the tax may be challenged before the tax court, as a measure function to advise the taxpayer of a particular tax claim, against which arises under 'Art.100 cpc the interest of the taxpayer to justice for the lawfulness of the tax claim, nothing in noting that such a notice does not appear explicitly in the list of documents contained in appeal. 19 of Legislative Decree no. N.546/92, as this list is to be interpreted broadly, both in deference to the constitutional protection of the taxpayer and sound public administration, which as a result of enlargement of the fiscal court actions n.448/01 with the law ... "
From this statement follows a principle equally clear: the taxpayer , recipient of the notice of administrative detention, has a specific interest and to review the legality of the alleged mail invoked to justify the injunction.
The thesis of not contesting the notice of administrative detention was, rightly, "cash".
Equitalia, while facing a major debate in case law that requires the above action by the United Sections of the Supreme Court, has always maintained, for obvious interest, non-actionable independent of the notice .
So dear readers, today more than ever, do not trust what he writes by the Collection Agent of the notice of administrative detention.
... leges bonae Malis ex moribus procreantur ... "(sometimes good laws are born of bad manners)
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