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 Issue A is resolved and withdrawn after supporting records are verified; issue B remains disputed.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?
- Every original issue must remain forever
- Subsequent assessment notices must be anchored only on issues remaining unresolved after the discrepancy discussion
- No later notice may explain its basis
- A resolved issue automatically becomes a criminal conviction
- 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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