More to Follow / Nica Marsha Gasapo
The proper issuance of a letter of authority (LOA), which is a written official authority issued by the Bureau of Internal Revenue (BIR) to its representatives to conduct a tax audit, is a strict legal requirement for the validity of a BIR tax assessment. The LOA informs the taxpayer that an audit or examination of its books of account will be conducted by the BIR through the authorized representatives specifically named therein. Without a valid LOA, an assessment is void for violating the taxpayer’s right to due process of law. In this article, we will discuss recent rulings of the Court of Tax Appeals (CTA), as well as common issues involving LOAs, memoranda of assignment, “revalidation or reassignment notices” and the like.