OUR National Internal Revenue Code, as amended (Tax Code), empowers the Commissioner of Internal Revenue (CIR) to conduct an assessment of the taxes paid by a taxpayer through the CIR's duly authorized representative armed with a validly issued Letter of Authority (LOA).
OUR National Internal Revenue Code, as amended , empowers the Commissioner of Internal Revenue to conduct an assessment of the taxes paid by a taxpayer through the CIR's duly authorized representative armed with a validly issued Letter of Authority . The Supreme Court has consistently ruled that an assessment conducted without a valid LOA is void .
At that point, the BIR was constrained to conduct a reinvestigation, pursuant to the taxpayer's request and for it to be able to issue a Final Decision on the Disputed Assessment to resolve the said protest.
LOA Needed During Reinvestigation Of Taxpayer's Protest
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