Cassation court allows taxpayer's appeal, ruling notification date for tax assessment matters the sending date, not receipt.

The court allowed the taxpayer's appeal against a regional tax commission decision regarding the statute of limitations for a 2006 property tax assessment. While the lower court relied on the recipient's date of January 2011, the Supreme Court held that for substantive tax acts, the principle of subjective notification applies, making the sending date in December 2010 the legally relevant one. Consequently, the court quashed the lower decision and rejected the taxpayer's original claim, noting that the power of taxation had not expired.