Despre prezumții în legislația și jurisprudența fiscală

The present study proposes a theme approached in a vision of mirroring a traditional institution in the matter of evidence in the reflection of tax legislation. The concept of presumption, used also by tax law, both in the sense of a tax rule and in the sense of an element of emerging administrative and judicial procedures raises questions not only about its content, but also about the role played in the way of distribution of the burden of proof of the fiscal legal relationship. The study proposes an inventory of legislation, at a formal and conceptual level, and a jurisprudence analysis regarding presumptions and their role in the tax law plan.