ONE HUNDRED AND FORTY-TWO PAGES, FIVE PUBLIC REGISTERS, TWENTY-SEVEN MONTHS, ZERO ANSWERS

On 22 July 2019, the defence filed with the AEAT the application for the full nullity of the Alicante assessments (DOC-0195): 142 pages. It was not rhetoric — it was an evidentiary package from five public registry sources, all official, all verifiable: the certificate from the Alicante municipal register; the Social Security work-history reports; the income tax returns for 2011, 2012 and 2014; the building invoices with identified clients; and the utilities — water, electricity, gas, mutual insurance — registered in his name at Trokabide, the address the notifications "could not find".

Five registers of the State itself proving, in a single file, that the "untraceable man with no activity" lived, worked, declared and paid bills exactly where the AEAT was supposed to notify him.

The law grants six months to resolve a nullity. The Ministerial Order arrived on 25 October 2021 (A.59): twenty-seven months later. And here the decisive thing is not the delay — it is the content. Neither the Legal Service report, nor the Council of State opinion, nor the Order that dismissed it examines a single one of the five registry sources. Not the municipal register, not the work history, not the income tax, not the invoices, not the utilities. Zero mentions.

Twenty-seven months to not read 142 pages. The administration did not respond to the evidence: it responded despite it. It is the administrative twin of what the reader already saw in court — evidence handed over in person and ignored — and it is, in itself, a ground for the State's financial liability.