SOME taxpayers may have experienced preparing and submitting extensive documents to the Bureau of Internal Revenue (BIR) to challenge a deficiency tax assessment, only to have their arguments and evidence ignored.
SOME taxpayers may have experienced preparing and submitting extensive documents to the Bureau of Internal Revenue to challenge a deficiency tax assessment, only to have their arguments and evidence ignored.
More importantly, the BIR officers failed to address any of the taxpayer's refutations in the letter-reply to the PAN, which the CTA deemed as an indication that the BIR did not take these into account when issuing the FAN.– The details of discrepancies in the FAN merely reiterated or copied verbatim the PAN's content, with only an adjustment to the interest imposed.
Due Process Matters In Tax Assessments
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