Author Archives: Rey Lozada

Letter Notice (LN) is considered notice of audit or investigation as far as amendments of Returns.  Once taxpayer received an LN, taxpayer can no longer amend tax returns in relation to the years covered by the LN. The guidelines provided under RMC 40-2003 in the issuance of LN has been upheld in the CTA CaseContinue reading “On Letter Notice (LN)”

The request for reinvestigation and reconsideration was in effect considered denied by CIR when the latter filed a civil suit for collection of defiency income tax. – CIR vs Union Shipping, G.R. No. L-66160, May 21, 1990.

Revenue Regulation No. 12-99, September 6, 1999. 3.1.2 Preliminary Assessment Notice (PAN). If after review and evaluation by the Assessment Division, or by the Commissioner or his duly authorized representative, as the case may be, it is determined that there exists sufficient basis to assess the taxpayer for any deficiency tax or taxes, the saidContinue reading “On PAN”

GR#222743, April 5, 2017Medicard vs CIR Highlights The absence of a LOA violated Medicars’ right to due process.An LOA is the authority given to the appropriate revenue officer assigned to perform assessment functions. It empowers or enables said revenue officer to examine the books of account and other accounting records of a taxpayer for theContinue reading “On LOA”