The appeal against the mortgages must be submitted in the "territory" in which the collection agent who issued the contested act, not according to the place where the property is situated members to mortgage. This is because the local jurisdiction of the tax court should be established with reference to the place where is located the headquarters of the local office of the Inland Revenue or the collection of the dealer who issued the act. To clarify it and the CTP of Reggio Emilia Judgement No 169/1/10
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