Practice question
An NOD states only “tax discrepancy exists” and gives neither the affected transactions nor a usable explanation. The examiner refuses details but demands that the taxpayer disprove the entire audit. Under RMO 1-2026, which is correct?
- The NOD must identify discrepancies clearly and specifically enough to permit an informed explanation and contest
- A vague accusation always satisfies due process
- Details are forbidden until collection
- Only the examiner’s private working notes need contain the issues
- The taxpayer must guess every possible transaction
Legal references
- https://bir-cdn.bir.gov.ph/BIR/pdf/RMO%20No.%201-2026.pdf — RMO 1-2026, section IX(B)–(C), page 12
- https://www.bir.gov.ph/2020-Revenue-Regulations — official RR 22-2020 listing; section 2 amending RR 12-1999 section 3.1.1
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