Practice question
In the audit circumstances addressed by Standard Insurance, the original named officers finish their work. Different officers reopen and investigate a discrepancy without a new LOA naming them. The BIR relies only on a letter notice, internal assignments and superior approval of reports. What did the Court hold?
- The missing required LOA invalidated the unauthorized audit and resulting assessment; those substitutes were insufficient
- A superior's signature automatically cured every authority defect
- A letter notice was the required new LOA
- Any officer could take over because the taxpayer had once been audited
- The court held that LOAs were merely optional
Legal references
- NIRC Sections5–6,13 and228: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
- CIR v. Standard Insurance, GR259729, November17 2025, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70327
- CIR v. Elric Auxiliary Services, GR226945, February19 2026, main decision: https://lawphil.net/judjuris/juri2026/feb2026/gr_226945_2026.html
- BIR RMO1-2026 official digest: https://bir-cdn.bir.gov.ph/BIR/pdf/RMO%20No.%201-2026%20Digest.pdf
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