Le mécanisme de solidarité traverse le droit fiscal. D’essence civile, la solidarité est intimement liée aux moyens de recouvrement dont dispose l’administration. S’agissant du dirigeant de société, sa « responsabilité pécuniaire » ou « solidarité patrimoniale » est actuellement suspendue à la décision du juge. Or, deux textes prévoient la solidarité du dirigeant selon qu’il s’agisse du juge de la responsabilité (LPF, art. L. 267) ou du juge répressif (CGI, art. 1745). Si ces deux dispositions sont indépendantes l’une de l’autre au motif qu’elles n’ont ni la même cause, ni le même objet, ni le même demandeur, il y a lieu de s’interroger sur leur portée respective, souligner leurs écueils et présenter les voies d’une réforme de la solidarité du dirigeant au passif fiscal. Il s’agit à la fois à rendre davantage efficace l’action en recouvrement de l’administration et garantir les droits dont dispose le dirigeant. La prégnance de la situation actuelle impose le pragmatisme : recouvrer le passif fiscal formé essentiellement par la TVA et suspendre la solidarité à l’intentionnalité des manquements à l’origine du passif fiscal dès la procédure d’assiette. / Joint liability is a recurrent feature of tax law. It is essentially a civil law mechanism which is closely bound to the means of recovery available to the revenue authorities. With respect to the company director, his “financial liability” or “joint pecuniary liability” currently depends on a court ruling. Two items of legislation provide for the director’s liability according to whether the matter is being heard before the civil courts (Article L. 267 of the LPF tax code) or the criminal courts (Article 1745 of the CGI tax code).Although those two provisions are independent from one another since they have neither the same legal basis, nor the same purpose and the person bringing the action is different, it is appropriate to question their respective scope, underline their pitfalls and present avenues for reform of the corporate manager’s joint liability for tax liabilities.The aim is both to make the revenue authority’s action for recovery more effective and to secure the corporate manager’s rights. The current situation requires pragmatism, for recovering tax liabilities resulting primarily from VAT and for suspending joint liability for intentionally causing tax liabilities from the time of the procedure of the determination of the tax base.

Map of Boone Reservoir Properties published in October 1959 by the Tennessee Valley Authority, Division of Reservoir Properties. The Boone Lake Property Map series is divided into 3 sheets, this is sheet 3 of 3. The legend denotes retained, surplus, or transferred land. Boxes on the top right quadrant include information such as approximate acreage of tracts and forecasted usage of retained lands. Property owners (as of 1959) are listed and are also included on the map itself. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = 2000' / https://dc.etsu.edu/rare-maps/1020/thumbnail.jpg

Map of South Holston Reservoir Properties published in October 1960 by the Tennessee Valley Authority, Division of Reservoir Properties. Compiled from Maps and Surveys "C" stage reservation maps.The South Holston Reservoir Property Map series is divided into 3 sheets, this is sheet 1 of 3. The legend denotes retained, surplus, or transferred land. Boxes on the bottom right quadrant include information such as approximate acreage of tracts and forecasted usage of retained lands. Property owners are included on the map itself. Some items, hand written in black ink, were added at an indeterminate time post publication. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = 2000' / https://dc.etsu.edu/rare-maps/1021/thumbnail.jpg

Map of South Holston Reservoir Properties published in October 1960 by the Tennessee Valley Authority, Division of Reservoir Properties. Compiled from Maps and Surveys "C" stage reservation maps.The South Holston Reservoir Property Map series is divided into 3 sheets, this is sheet 2 of 3. The legend denotes retained, surplus, or transferred land. Boxes on the top right quadrant include information such as approximate acreage of tracts and forecasted usage of retained lands. Property owners are included on the map itself. Some items, hand written in black ink, were added at an indeterminate time post publication. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = 2000' / https://dc.etsu.edu/rare-maps/1022/thumbnail.jpg

Map of South Holston Reservoir Properties published in October 1960 by the Tennessee Valley Authority, Division of Reservoir Properties. Compiled from Maps and Surveys "C" stage reservation maps.The South Holston Reservoir Property Map series is divided into 3 sheets, this is sheet 3 of 3. The legend denotes retained, surplus, or transferred land. Boxes on the bottom right quadrant include information such as approximate acreage of tracts and forecasted usage of retained lands. Property owners are included on the map along property lines. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = 2000' / https://dc.etsu.edu/rare-maps/1023/thumbnail.jpg

Map of Watauga Reservoir Properties published in October 1959 by the Tennessee Valley Authority, Division of Reservoir Properties. Compiled from Maps and Surveys "C" stage reservation maps.The Watauga Reservoir Property Map series is divided into 3 sheets, this is sheet 1 of 3. The legend denotes retained, surplus, or transferred land. Boxes on the bottom right quadrant include information such as approximate acreage of tracts and forecasted usage of retained lands. Lake front property owners (as of 1959) are listed as well included on the map itself. A map key for all 3 sheets is included on the top left corner. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = 2000' / https://dc.etsu.edu/rare-maps/1024/thumbnail.jpg

Map of Watauga Reservoir Properties published in October 1959 by the Tennessee Valley Authority, Division of Reservoir Properties. Compiled from Maps and Surveys "C" stage reservation maps.The Watauga Reservoir Property Map series is divided into 3 sheets, this is sheet 2 of 3. The legend denotes retained, surplus, or transferred land. The box on the lower half includes information such as approximate acreage of tracts and sale or transfer designation. Lake front property owners (as of 1959) are listed on the top left quadrant as well included on the map itself. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = 2000' / https://dc.etsu.edu/rare-maps/1025/thumbnail.jpg

Navigation Map of Cherokee Reservoir Holston River published in 1955 by the Tennessee Valley Authority, Maps and Surveys Branch. Sheet 1 of a series of 4 maps covering Cherokee Reservoir. This sheet covers mile 52.3 to mile 62.8. The Index to all 4 maps can be found on the lower right quadrant. The legend denotes several information items pertaining to lake levels, direction of flow, bridges, and other points of interest. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = .5 mile. Datum is mean sea level. / https://dc.etsu.edu/rare-maps/1027/thumbnail.jpg

Navigation Map of Cherokee Reservoir Holston River published in 1957 by the Tennessee Valley Authority, Maps and Surveys Branch. Sheet 4 of a series of 4 maps covering Cherokee Reservoir. This sheet covers mile 95.1 to mile 116.6. The inset located in the upper portion includes a detailed view of Miller Island and Honeycutt Creek. The legend denotes several information items pertaining to lake levels, direction of flow, bridges, and other points of interest. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = .5 mile. Datum is mean sea level. / https://dc.etsu.edu/rare-maps/1028/thumbnail.jpg

Navigation Map of Cherokee Reservoir Holston River published in 1956 by the Tennessee Valley Authority, Maps and Surveys Branch. Sheet 3 of a series of 4 maps covering Cherokee Reservoir. This sheet covers mile 79.3 to mile 95.1. The index to the entire 4 maps series can be found in the lower right quadrant. The legend denotes several information items pertaining to lake levels, direction of flow, bridges, and other points of interest. Physical copy resides in the Government Information, Law and Maps Department of East Tennessee State University’s Sherrod Library. Scale: 1" = .5 mile. Datum is mean sea level. / https://dc.etsu.edu/rare-maps/1029/thumbnail.jpg