Philippine Bar review · Question

Practice question: Notice of Discrepancy

Multiple Choice Hard

Practice question

Two NOD issues are discussed. Issue A is resolved and withdrawn after supporting records are verified; issue B remains disputed. The examiner later includes A again solely to increase the assessment, without identifying any unresolved issue concerning it. What does RMO 1-2026 direct?
  1. Every original issue must remain forever
  2. Subsequent assessment notices must be anchored only on issues remaining unresolved after the discrepancy discussion
  3. No later notice may explain its basis
  4. A resolved issue automatically becomes a criminal conviction
  5. The taxpayer’s evidence must be discarded

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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