Practice question
An LOA authorizes named revenue officers to audit a specified taxpayer and period. Different officers later conduct the examination that produces a new deficiency assessment, but no new LOA or legally sufficient authority for them is issued. The BIR relies only on an internal reassignment memorandum. Under Standard Insurance, which objection is strongest?
- Any employee can audit every taxpayer by virtue of employment alone
- An accurate arithmetic result automatically cures lack of audit authority
- The taxpayer’s business size supplies authorization
- A reassignment memorandum is always identical to an LOA
- The examining officers require the proper authority; the stated reassignment alone does not cure the LOA defect
Legal references
- NIRC Sections6,13 and228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- CIR v. Standard Insurance, G.R.259729, November17 2025: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70327
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