COURT OF TAX APPEALS DECISIONS An assessment is void for violating due process when the BIR issues a Formal Letter of Demand/Final Assessment Notice (FLD/FAN) before the lapse of the 15-day period to respond to a Preliminary Assessment Notice (PAN). The BIR must observe due process by granting the taxpayer
COURT OF TAX APPEALS DECISIONS The tax assessment is void if the BIR failed to prove proper service of the Notice of Informal Conference and Preliminary Assessment Notice (PAN); procedural requirements in substituted serve must be complied with; unverified sources like newspaper clippings and third party sources cannot be a
COURT OF TAX APPEALS (CTA) DECISIONS Different due dates renders the assessment void for lack of a clear, unequivocal payment deadline. A valid Final Assessment Notice/Formal Letter of Demand (FAN/FLD) must contain two essential elements: a definite demand for a specific amount of tax liability and a clear, unequivocal due