THE APPEALS THAT WARNED IN TIME

Let no one say there was no warning. On 3 October 2016, Apolozan filed a formal appeal with the Tax Agency — entry register RGE030360492016 — against the machinery that had been set in motion towards Romania (A.42).

The brief put on the table, in the midst of the enforcement phase and with everything still reversible, the elements this portal documents: that the notifications of the debt had not been served at the address recorded in the AEAT's own system; that the administration was withholding VAT balances of the taxpayer himself while enforcing against him a debt smaller than what was withheld; and that the file travelling to Romania carried the defects of origin of the GAUZATU case.

This date matters for what it defines legally: from 3 October 2016 onwards, no subsequent action can shelter behind ignorance. The administration was warned in writing, with official registration, of the defects in its title — and chose to continue. In administrative law that decision has consequences: what before could be error, after the warning is a choice.

The appeal met the fate of almost all that would follow: dismissal. But it left what it had to leave — the record. The file could no longer say it did not know.