Procedural Due Process in Tax Assessments

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1. What must a tax assessment communicate in writing under Section 228?
2. Under the current discrepancy-stage framework, what notice replaced the former Notice of Informal Conference?
3. Which is an express Section 228 exception to issuance of a preassessment notice?
4. A Notice of Discrepancy identifies audit discrepancies and invites the taxpayer to explain with supporting documents. T…
5. A true mathematical-error case satisfies a statutory PAN exception. The BIR argues that this also excuses it from infor…
6. An LOA authorizes named revenue officers to audit a specified taxpayer and period. Different officers later conduct the…
7. A corporation timely challenges a formal deficiency assessment that states only a lump-sum amount and a bare demand, wi…
8. Explain the purpose of the Notice of Discrepancy and discrepancy discussion in the current assessment framework.
9. Distinguish a valid Letter of Authority from the written factual and legal basis of a tax assessment.
10. Why is it incorrect both to say a PAN is required without exception and to say a PAN exception validates every resultin…
11. If a taxpayer specifically denies receiving a required PAN, does a bare assertion that the BIR mailed one automatically…
12. What response opportunity is discussed in Prime Steel for a taxpayer receiving a PAN where no exception applies?