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TAX REMEDIES

UNDER

NIRC

I. A.

Assessment of Internal Revenue Taxes Definition/nature/effect/basis 1. Meaning of tax assessment It is the official action of an officer authorized by law in ascertaining the amount of tax due under the law from a taxpayer. This action necessarily involves: a. the computation of the sum due; b. giving notice to that effect to the taxpayer; and c. the making simultaneously with or sometime after the giving of notice of a demand upon him for the payment of the tax deficiency stated.

2. Tax audit is the process of examining going over or scrutinizing the books and records of
the taxpayer to ascertain the correctness of the tax declared and paid by the taxpayer. It can only be performed upon a !etter of "uthority issued by the #ommissioner or $egional %irector.

3. Letter of Authority is a commission granting a revenue officer assigned to perform


assessment functions the power to conduct an examination of the books and records of a taxpayer within the &urisdiction of the district in order to collect the correct amount of tax or to recommend the assessment of any deficiency tax due.

4. Pre-assessment notice ' is a written notice given to a taxpayer informing him of the findings
of the (I$ officer)s relating to a deficiency in his tax return indicating therein the law and the facts on which the assessment is made and re*uiring the taxpayer to respond within a given period otherwise the #ommissioner or his duly authorized representative shall issue an assessment based on his findings. Instances where pre'assessment notice +,T re*uired: a. when the finding for any deficiency tax is the result of mathematical error in the computation of the tax as appearing on the face of the return; b. when the discrepancy has been determined between the tax withheld and the amount actually remitted by the withholding agent; c. when a taxpayer who opted to claim a refund or tax credit of excess creditable withholding tax for a taxable period was determined to have carried over and automatically applied the same amount claimed against the estimated tax liabilities for the taxable *uarter or *uarters of the succeeding taxable year; d. when the excise tax due on excisable articles has not been paid; e. when an article locally purchased or imported by an exempt person such as but not limited to vehicles capital e*uipment machinery and spare parts has been sold traded or transferred to non'exempt persons.

5. Notice of assessment a notice given to the taxpayer by the (I$ informing him of the
amount of deficiency tax for which the taxpayer is being assessed based on the findings of the (I$ upon failure of the taxpayer to respond to the pre'assessment notice or after an examination has been conducted.

6. Deficiency the amount by which the tax properly due exceeds the sum of the amount of the
tax shown on a taxpayer-s return plus amounts previously assessed or collected as deficiency less any credits refunds or other payments due the taxpayer; the amount a taxpayer is deficient in his tax payments.

Delinquency The state of a person upon whom the personal obligation to pay the tax has been fixed by lawful assessment and thereafter fails to pay the tax within the time limited by law.

7. Jeo ardy assessment an assessment made demanding immediate payment of the tax due
without the usual formalities in instances when the #ommissioner believes that if the tax will be collected under normal procedures the collection of such tax is at risk which might result in loss to the government. Instances when &eopardy assessment may be issued: .hen it shall come to the knowledge of the #ommissioner that a taxpayer is: a. retiring from business sub&ect to tax; or b. intending i. to leave the /hilippines or remove his property therefrom; or ii. to hide or conceal his property; c. performing any act tending i. to obstruct the proceedings for the collection of the tax for the past or current *uarter or year; or ii. to render the same totally or partly ineffective unless such proceedings are begun immediately. 01ec. 2% $.". 34546

8. Po!er of the "ommissioner to assess deficiency tax based on best e#idence obtainable
1ec. 2( of $.". 3454 empowers the #ommissioner to assess the proper tax and make or amend the return based on the best evidence obtainable 0from his own knowledge and from such information as he can obtain through testimony or otherwise6 when: a. a report re*uired by law as a basis for the assessment of any national internal revenue tax shall not be forthcoming within the time fixed by laws or rules and regulations; or b. there is reason to believe that any such report is i. false ii. incomplete iii. erroneous. The return made by the #ommissioner in this instance shall be prima facie correct and sufficient for all legal purposes.

9. $equisites of a #alid assessment a. post'reporting notice or notice for an informal conference after the tax audit b. /re'assessment notice if re*uired c. Issuance and receipt of +otice of "ssessment i. must be issued prior to lapse of prescriptive period ii. the written notice must state the facts and the law upon which the assessment is
based

1ec. 4. Power of Commissioner to Interpret Tax Laws and Decide Tax Cases

/ower to interpret provisions of +I$# and other tax laws exclusive and original &urisdiction of #I$; review by 1ec. of 7inance. #ommissioner has power to decide disputed assessments refunds of internal revenue taxes fees or other charges penalties imposed in relation thereto other matters arising under the +I$# or other laws administered by (I$ 8xclusive appellate &urisdiction of the #T". 8xclusive and ,riginal 9urisdiction #I$ #I$ $eview)"ppeal 1ec. of 7inance 0review6 8xclusive "ppellate 9urisdiction of #T"

Interpretation of tax laws %eciding tax cases

1ec. :. Power of Commissioner to Obtain Information, and to Summon, Examine, and Take Testimony of Persons To carry out #I$-s function of: "scertaining correctness of any return ;aking a return where none has been made %etermining the liability of any person for any revenue tax #ollecting tax liabilities 8valuating tax compliance #ommissioner is empowered:

1. to examine books paper records and other data 2. to obtain any information such as
a. costs and volume of production b. receipts or sales and gross incomes of taxpayers c. names addresses and financial statements of i. corporations ii mutual fund companies iii. insurance companies iv. regional operating head*uarters of ;+#s v. &oint accounts vi. associations vii. &oint ventures or consortia viii. partnerships Information may be obtained from "ny person other than the taxpayer "ny office or officer of national and local governments government agencies and instrumentalities including (1/ <,##s =. to summon the person liable for tax or re*uired to file the return

any person having possession books of accounts custody of the other accounting records care any other person

of the person liable for tax

to appear before the #ommissioner or his duly authorized representative to produce such books papers records or other data and to give testimony 4. to take testimony of persons concerned :. to cause revenue officers and employees to make a canvass of any revenue district or region and in*uire after and concerning all persons therein who may be liable to pay any internal revenue tax all persons owning or having the care management or possession of any ob&ect with respect to which a tax is imposed. >owever the #ommissioner-s authority to in*uire into bank deposits shall be limited to: (ank deposits of a decedent to determine his)her gross estate (ank deposits of a taxpayer who has filed an application for compromise of his tax liability by reason of financial incapacity .aiver in writing of taxpayer-s privilege under (ank 1ecrecy !aw $e*uired when applying for compromise of tax liability by reason of financial incapacity; such waiver constitutes the #ommissioner-s authority to in*uire into bank deposits of the taxpayer. 1ec. 2. /ower of #ommissioner to ;ake "ssessments and /rescribe "dditional $e*uirements for Tax "dministration and 8nforcement

A. 8xamination of returns and determination of tax due - Tax returns filed by taxpayers as basis for examination - .hen no tax return has been filed examination may proceed based on other data obtained by #ommissioner Tax or deficiency tax assessed payable upon notice and demand from #ommissioner or duly authorized representative Tax return statement or declaration once filed cannot be withdrawn ' may only be modified changed or amended within three years from filing before any notice for audit or investigation has been actually served the taxpayer

B. 7ailure to submit re*uired returns statements reports and other documents - empowers the #ommissioner to assess the proper tax based on the best evidence obtainable - #ommissioner shall make or amend the return from his own knowledge and from such
information as he can obtain through testimony or otherwise; such information deemed prima facie correct and sufficient for all legal purposes. conditions: - when a report re*uired to be filed is not forthcoming within the time fixed by law. - when there is reason to believe that any such report is false incomplete or erroneous.

C. "uthority to conduct inventory'raking surveillance and to prescribe presumptive gross sales and
receipts

when there is reason to believe that a taxpayer is not declaring his correct income sales or receipts for income tax purposes the #ommissioner may - order inventory'taking of goods of goods 0to be used as basis for determining taxpayer-s internal revenue liabilities6 - place the business operations of the taxpayer under observation or surveillance findings shall be used as basis for assessing the taxes for the other months or *uarters of the same or different taxable years. when there is failure to issue receipts and invoices or when there is reason to believe that the books of accounts or other records do not correctly reflect the declarations made in tax returns #ommissioner may prescribe a minimum amount of such gross receipts sales and taxable base based on the sales receipts income or other taxable base of other persons engaged in similar businesses under similar situations or circumstances

D. "uthority to terminate taxable period - #ommissioner shall declare the tax period of any taxpayer terminated at any time when it shall
come to the knowledge of the #ommissioner that a taxpayer - is retiring from business sub&ect to tax - is intending to leave the /hilippines or to remove his property therefrom or to hide or conceal his property - is performing any act tending - to obstruct the proceedings for the collection of the tax for the past or current *uarter or year or - to render the same totally or partly ineffective unless such proceedings are begun immediately #ommissioner shall send the taxpayer: - notice of such decision - re*uest for the immediate payment of the tax for the period so declared terminated and the tax for the preceding year or *uarter or such portion thereof as may be unpaid - taxes due and payable immediately - taxes sub&ect to all the penalties and surcharges prescribed unless paid within the time fixed in the demand made by #ommissioner.

E. "uthority of #ommissioner to prescribe real property values - #ommissioner authorized to divide the /hilippines into different zones and assign valuation of real properties in the different zones ?alue of property for computing any internal revenue tax: whichever is >I<>8$ between 7;? as determined by #ommissioner and 7;? as shown in the schedule of values of the /rovincial and #ity "ssessors

F. "uthority of #ommissioner to in*uire into bank deposit accounts - #ommissioner is authorized to in*uire into bank deposits of: - a decedent to determine his gross estate - any taxpayer who has filed an application for compromise of his tax liability by reason of
financial incapacity - taxpayer must execute in writing a waiver of his right under (ank 1ecrecy !aw and other special laws such waiver serving as the #ommissioner-s authority to in*uire into his bank deposits

application for tax compromise shall not be considered without this written waiver

G. "uthority to accredit and register tax agents - #ommissioner shall accredit and register individuals and general professional partnerships and their representatives who prepare and file tax returns statements reports protests and other papers with or who appear before the (I$ for and in behalf of taxpayers #reation of +ational and $egional "ccreditation (oards Those whose application for accreditation is denied by the #ommissioner of the +ational or $egional "ccreditation (oards may appeal to the 1ecretary of 7inance 1ecretary of 7inance to act on appeal within 2@ days from receipt of such appeal 7ailure of 1ec. of 7inance to act on appeal deemed approval of the application for accreditation of the appellant.

H. "uthority of #ommissioner to prescribe additional procedural or documentary re*uirements - #ommissioner may prescribe the manner of compliance with any documentary or procedural
re*uirement in connection with the submission or preparation of financial statements accompanying the tax returns. 1ec. 5@= +I$# 1ec. 555'55= +I$# 1ec. 553 +I$# $ev. $eg. A5'3: /rocedure covering administrative protest on assessment by the (I$ #ommissioner $ev. $eg. B'C= 7iling of *uarterly income tax returns and payment of *uarterly income tax by individuals receiving self'employed income 1ec. 555 0e6 +I$# re: In*uiry into any return filed in accordance with the provisions of any tax amnesty law or decree as amended by (/ B@@ $ep. ?. I"# AC2 1#$" ==: (onifacio 1y /o v. #T" A24 1#$" :54 ;eralco v. 1avellano AAB 1#$" 3@4 8legado v. #T" AB= 1#$" 53: #ommissioner v. Island <arment A:= 1#$" 22: #ollector v. (enipayo 4 1#$" A35 #ommissioner v. #onstruction $esources A4: 1#$" 2BA ;arcos v. #" <.$. A5@33@ : 9une ACCB

B. /eriod to assess deficiency tax


A. prescription: = years A@ years 5. 1uspension of prescriptive period)8xceptions 1ec. 5@= +I$# of ACCB 1ecs. 555'5= +I$# of ACCB

$ead: $ev. ;emo ,rder 5@'C@ 04 "pril ACC@6 /roper execution of the waiver of the statute of limitations under the +I$#

$ev. ;emo ,rder 43'C@ 05= "pril ACC@6 #ounting of the three'year prescriptive period in issuance of notice of assessment or warrants of distraint levy and garnishment #ases: #I$ v. #T" AC: 1#$" 444 #ommissioner v. <onzales A3 1#$" B:B $e: prescriptive period to assess $epublic v. Derr A3 1#$" 5@ "znar v. #T" :3 1#$" :AC ,ptional: (asa v. $epublic A=3 1#$" =4 $epublic v. %ela $ama id.

II.

/rotesting an assessment)$emedy before payment

A. >ow to protest or dispute an assessment administratively


1ec. 553 +I$# of ACCB 1. 8ffect of protest)assessment deemed %I1/ET8% 2. 1uspension of the prescriptive period to collect 3. Two ways of protesting administratively a. $e*uest for reconsideration b. $e*uest for reinvestigation $ev. $eg. A5'3: /rocedure covering administrative protest on assessment by (I$ #ommissioner 4. %ifferences and similarities of protest cases under the Tariff and #ustoms #ode 5. /ayment under protest not re*uired under the +I$# 6. 2@'day period to submit relevant documents

B. 8ffect of failure to protest


1ec. 553 +I$# of ACCB ;arcos v. #" <.$. +o. A5@33@ : 9une ACCB ;ambulao !umber #o. v. $ep. A=5 1#$" A %ayrit v. #ruz A2: 1#$" :BA $e: 8ffect of abandoning the protest #om. ?. .yeth 1uaco 5@5 1#$" A5:

C. #ommissioner renders a decision on the disputed assessment 1. $emedy of the taxpayer if protest is denied: "ppeal to the #T" the final decision of
the #I$ on the disputed assessment.

2. $emedy of the taxpayer if the #I$ fails to act on the protest within A3@ days from 3. 4.
receipt of protest. 8ffect of failure to appeal .hat is the final decision of the #I$ on the disputed assessmentF

$ev. $eg. A5'3: 1ections 4 ) 553 +I$# of ACCB

1ection 553 +I$# of ACCB ;ambulao !umber v. $epublic id. ) civil action to enforce &udgment #ommissioner v. island <arment id. %ayrit v. #ruz id. #ommissioner v. Enion 1hipping A3: 1#$" :4B #ommissioner v. "lgue A:3 1#$" C "dvertising "sso. ?. #" A== 1#$" B2: ,ptional: 1urigao 8lectric v. #T" :B 1#$" :5= 7abular v. #" AAC 1#$" =5C 1t. 1tephen 1chool v. #ollector A@4 /hil. =A4

III.

#laims for refund and credit taxes)$emedy "7T8$ payment

A. .hen)>ow to file claim)prescriptive period


.ho may file for refundF Taxpayer)withholding agent $efund without claim /ayment under protest not a re*uirement 1ec. 5@4 0=6 +I$# as amended by $" 3454 $e: A@G and 4@G limit re: compromise amount $e*uisites if beyond the limit ,$ the basic tax is greater than /A; 1ec. 55C +I$# of ACCB #I$ v. /hilamlife <.$. A@:5@3 5C ;ay ACC: #I$ v. Tokyo 1hipping <.$. 235:5 5: ;ay ACC: 1an #arlos v. #I$ 553 1#$" A=: +ote: 1ection 5@4 as amended by $" 3454: " return filed showing an overpayment shall be considered as a written claim for credit or refund. #I$ v. #" and #itytrust 5=4 1#$" =43

B. 9udicial remedy of the taxpayer 1.


"ppeal to the #ourt of Tax "ppeals a. If #I$ denies the claim or re*uest =@ days from receipt of decision b. If #I$ fails to act on the protest within A3@ days ) =@ days to be counted from lapse of the A3@'day period. "ppeal by filing a petition for $eview ) /etition for $efund a. .ithin two years from date of payment to initiate &udicial proceedings 1ection 4 +I$# of ACCB 1ection 55C +I$#

2.

b. ;eaning of supervening causes c. =@'day period to appeal &urisdictional d. The 5'year period to initiate &udicial proceedings not &urisdictional but a e.
positive re*uirement The two periods 0=@ days and 5 years6 ;E1T concur #I$ v. /hilamlife <.$. +o. AC:5@3 5C ;ay ACC:

#I$ v. #" and "tlas #onsolidated 5=5 1#$" =5A #ollector v. /rieto 5 1#$" A@@B #I$ v. /alanca A3 1#$" 4C2 ;aceda v. ;acaraig 55= 1#$" 5AB #ommissioner v. T;H 1ales 5@: 1#$" A34 Gibbs v Com ! "# SCRA $"% Gibbs v Com ! "&' ()il *$* .hen <ibbs contributed to the withholding tax system he did not really deposit an amount to the #ommissioner of Internal $evenue but actually performed and extinguished his tax obligation for the year concerned. >e paid his tax liabilities for that year. " taxpayer whose income is withheld at the source will be considered to have paid his tax liability when the same falls due at the end of the year. It is from this date or when the tax liability falls due that the two'year prescriptive period starts to run with respect to payments effected through the withholding tax system. Com + Conce,cion! ** SCRA "&#% #oncepcion already re*uested for refund of estate and inheritance taxes at the (I$. >is re*uest denied he appealed to the #T" but was dismissed for having been filed beyond the reglementary period. "fter paying under protest he sued again this time for recovery. The #ourt said he can-t do this because the remedy of contesting the validity of an assessment cannot be revived when there is already a final prior &udgment dismissing the same on the ground of prescription. Com + (rocter and Gamble! *&- SCRA .#' The (I$ appealed a #T" decision granting to / I < /hilippines. 7or the first time on appeal however it raised the issue of / I < /hilippines not being the proper party to claim refund. It said that / I < E1" instead should make the claim. The #ourt said (I$ should not be allowed to do this because it had all the opportunity to ask about / I <-s capacity or authorization from its parent company at the administrative level. It is unfair and too late to ask for it now especially because this suit was filed &ust before the expiration of the two'year prescriptive period. ACCRA Investment vs CA The #ourt elaborates on the 0second6 <ibbs ruling saying that there are two alternative reckoning dates for a taxpayer whose income is withheld at source: (1) the end of the tax year and (2) when the tax liability falls due. In this case since "##$" Investments only knew its tax liability on "pril A: AC35 when it filed its return this date would be the reckoning date for the prescriptive period and not %ecember =A AC3A when the taxes withheld at source were paid and remitted to the (I$. (efore it filed its return "##$" was not sure of whether it made a profit or not. #ebu /ortland v. #ollector id. "guilar v. #" AC@ 1#$" ACC@

IV.

9urisdiction of the #ourt of Tax "ppeals $" AA5: the law creating the #T"

A. .hy was the #T" createdF B. C. D. E.


/hil. $efining #o. v. #" 5:2 1#$" 22A ,ptional: Ersal v. #T" A@A /hil. 5@C 9urisdiction of the #T" 7I+"! decisions of the #ommissioner of Internal $evenue on %I1/ET8% assessment ;eaning of disputed assessment .ho may appeal to the #T"F 1ec. AA $" AA5: 1ec. B $" AA5: as amended by $" =4:B +ew issues cannot be raised for the first time on appeal. .hat are the exceptionsF

!imitations:

#I$ v. /<'/;# 5@4 1#$" =BB 1ec. 5A3 +I$# !im v. #T" A@: /hil. CB4 #om. v. ?illa 55 1#$" 4 #om. v. 9oseph : 1#$" 3C: ;eralco 1ecurities v. 1avellano id.

V.

"ppeal from the #T" to the #ourt of "ppeals from the #" to the 1upreme #ourt /rescriptive period ;agsaysay !ines v. #" <.$. +o. AAAA34 A5 "ugust ACC2 !iboro v. #" AB= 1#$" 53: 1upreme #ourt #ircular A'CA as amended by 1upreme #ourt $evised "dministrative #ircular A'C:

VI.

#ollection of Internal $evenue Taxes

A. /rescriptive period to collect 1. 1ection 5@= = years 2. 1ection 555 : years


#om. v. .yett 1uaco 5@5 1#$" A5: $ev. $eg. A5'C= as amended by $ev. $eg. ='C4 $ev. $eg. A4'C= as amended by $ev. $eg. ='C4 $e: Tax payment by checks and by bank debit memo

VII.

$emedies "vailable to the <overnment

A. "dministrative remedies)1ummary remedies


1ecs. 5@='5=A +I$# #ommissioner v. .yett 1uaco 5@5 1#$" A5:

1. %istraint of personal property

%efinition)kind)procedure 1ecs. 5@2'5A5 +I$# 1ecs. 55A'555 +I$# $ev. $eg. ='2C

2. !evy of $eal property


%efinition)procedure 1ecs. 5A='5A3 +I$# $ev. $eg. ='2C ;arcos v. #" id.

3. 7orfeiture
1ec. 5A2 +I$# 1ecs. 554'552 +I$#

4. Tax lien
1ec. 5AC +I$# of ACCB $ev. ;emo #ircular 5'C4 $epublic v. 8nri*uez A22 1#$" 2@3 #ommissioner v. +!$# 5=3 1#$" 45 >ongkong and 1hanghai (ank v. $afferty =C 1#$" A4:

5. +o in&unction to restrain collection of taxes


1ec. 5A3 +I$# $eview: +orthern !ines v. #T" A2= 1#$" 5: 8xception: #T" 1ec. AA $" AA5: #onditions for the issuance of in&unction

B. 9udicial remedies
#ivil)criminal action $e*uirements in filing criminal)civil cases 1ecs. 55@'55A +I$# Engab v. #usi CB 1#$" 3BB #om. v. #" 5:B 1#$" 5@@ 0!ucio Tan)7ortune Tobacco #ase6 $esolution on the ;otion for $econsideration B 7ebruary ACCB

VIII.

1tatutory ,ffenses and /enalties

A. #ivil /enalties)1urcharges)Interest
1ec. 543'5:A +I$# of ACCB

1. "pplicable interest rate 5@ G ) ;anila $eference $ate : .hichever is higher 2. #omputation of interest)basis
$ev. $eg. ='CA 0A'54'CA6 Implementing 1ec. 5C4 of the +I$#)/rescribing a deficiency rate of interest higher than 5@G per annum

3. 1urcharge 5:G :@G

a. 7alse return v. fraudulent return b. 7raud assessment c. ;andatory imposition of penalties


#ases: 9avier v. #om. ACC 1#$" 354 "znar v. #ollector :3 1#$" :AC #astro v. #ollector 2 1#$" 332 Issuance)printing of receipts registration of name)violations)penalties 1ecs. 5=2'54= +I$# 1ec. 52= +I$#

B.

C. #ompliance re*uirements 1. Deeping of books of accounts 2. 1ecuring tax identification number 0TI+6 3. "ttachments to tax returns: #ertificate of tax compliance
$ev. $eg. ='C@ 1ecs. 5=5'5=2 +I$# $ev. $eg. AA'3C $egistration of books of accounts $ev. ;emo #ircular A='35 /rocedures in the issuance of permits to use loose leaf books of accounts records invoices and receipts $ev. $eg. A='C= $e: Issuance and use of TI+ $ev. ;emo #ircular +o. 2='CA Issuance of the +ew TI+ 0Tax Identification +umber6 to taxpayers and its use on documents and receipts

D. #rimes)offenses)penalties)forfeitures 1. $evised penalties


1ecs. 554'553 +I$# as amended by $" B245 $ev. $eg. 4'C4 1ec. 5:: as amended by $" B4CB 1ecs. 5:='53A +I$#

a. 8lements of tax evasion b. /ersons liable in case taxpayer is a &uridical entity c. /ayment of tax +,T a valid defense 2. /rescription of violations of the +I$#
$ev. ;emo #ircular A@A'C@ dated 52 +ov. ACC@ %etermination of when cause of action for wilfull failure to pay deficiency tax accrue and prescription under 1ec. 53A +I$# !im v. #" AC@ 1#$" 2A2

Engab v. #usi CB 1#$" 3BB /eople v. Tierra A5 1#$" 222 "znar v. #T" :3 1#$" :AC #om. v. 9"! 5@5 1#$" 4:@

IX.

"batement of tax ) Tax #ompromise 1ection 5@4 +I$# of ACCB

A. "uthority of the #ommissioner to abate taxes 1. 2.


<rounds for abating taxes and penalties #onditions

$ead: $;, 4:'C= as amended by $;, :4'C=

B. /ower to compromise ) discretionary power 1. <rounds)reasons for a compromise agreement 2. #ases that cannot be compromise 3. 1ub&ect to limitations a. If reason is financial incapacity +,T less than A@G of basic tax b. ,ther cases not less than 4@G of basic tax c. .ould re*uire approval of the (oard: i. (asic tax assessment /A; ii. ,r below the prescribed limits 4. <overnment-s remedy if taxpayer fails to comply with the agreement
1ec. 5@4 +I$# of ACCB $ev. $eg. A5'C= Implementing <uideline for $" B242 $ev. ;emo ,rder 4:'C= as amended by $;, :4'C= 8xample: abatement of penalties $ev. ;emo ,rder =5'C5 as amended by $;, 55'C4 $ev. ;emo ,rder A'C@ as amended by $;# AB'C@ 8xample schedule of compromise penalties

X.

Informer-s $eward 1ec. 535 +I$# of ACCB $ev. ;emo ,rder +o. A5'C= dated A 7ebruary ACC= <uidelines in the filing of confidential information for violation of the +I$# and investigation by authorized revenue officer. ;eralco 1ecurities v. 1avellano AAB 1#$" B@4 /enid v. ?irata A5A 1#$" A22 #om. of Internal $evenue v. #om. on "udit 5A3 1#$" 5@=

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