Preliminary Assessment Notice

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1. What is the ordinary purpose of a Preliminary Assessment Notice in a deficiency-tax investigation?
2. What is the ordinary period to respond to a PAN under RR 12-1999, as applied in Prime Steel Mill?
3. Which deficiency finding is expressly a statutory exception to the PAN requirement under NIRC section 228?
4. A taxpayer receives a PAN and submits its written response ten days later. Is that response outside the ordinary fiftee…
5. An auditor determines a discrepancy between tax actually withheld and the amount remitted by the withholding agent. Doe…
6. A taxpayer receives a PAN on day zero and has not replied. On day seven the BIR issues its FLD/FAN, before the fifteen-…
7. A taxpayer disputes alleged unreported sales using reconciliations and invoices in a timely PAN response. The BIR ignor…
8. Explain the PAN’s function and the ordinary response period, distinguishing it from a final assessment protest.
9. Give two express section 228 exceptions to the PAN requirement and explain why they do not establish a universal power …
10. Under Prime Steel Mill, evaluate issuance of an FLD/FAN before the taxpayer’s fifteen-day PAN response period expires w…
11. Section228 recognizes a PAN exception when what remains unpaid?
12. Which transfer is expressly described in Section228(e)’s PAN exception?