RO recommends the cancellation of

the entire assessment;

-issuance of Authority to Change
Administrative Remedies of Government Assessment (ATCA) might be necessary
to remove the receivable account from
Assessment & Collection Process the TP

RO recommends the issuance of a

Examination of books of Submission revised assessment;
accounts and other Issuance of Formal of Relevant -Issuance of ATCA is only necessary only
Issuance of Supporting w/ respect to the items or deductions that
accounting records of the Notice of Informal Assessment Notice
Preliminary Documents have been deleted from the original
taxpayer by revenue Conference (FAN) & Letter of
Assessment Notice within 60 assessment on account of the additional
officers to determine his Demand days from evidence presented by TP
correct tax liability -If TP agrees w/ RO’s
findings  TP pays the -TP has 15 days to respond filing letter of
deficiency tax from receipt of notice protest
RO recommends the denial of all items
-If TP is not amendable  -No response = default
in the protest
TP is informed by RDO or -exceptions to PAN (See CIR has 180 days to
SPD of NIC to air TP’s side Sec.228 of NIRC) act on the protest
of the case
-TP has to respond w/in 15 -Reply (as -Protest
days from receipt of NIC remedy) w/in (remedy) w/in
-No response = TP is in 15 days after 30 days after
default the receipt of receipt of FAN
PAN

Modes of Protest:
-Request for Reconsideration
-Request for Reinvestigation

If protest was denied by the Commissioner Appeal to CTA w/30 days from the lapse of 180
Denial of Protest -appeal to CA w/in 30 days from the receipt of days after submission of the docs supporting the
by the decision otherwise the assessment shall Appeal by TP of the final decision protest at the BIR level; or
Commissioner or become final, executory and demandable of the Commissioner or his
the authorized authorized representative on the
representative If protest was denied by RO lower than disputed assessment to the CTA
Commissioner Wait until the Commissioner decides on the
-elevate TP’s protest to Commissioner w/in 30 protest before elevating the case to the CTA
days from receipt of the decision.
ADMINISTRATIVE APPEAL

KGK Notes