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Clarification on the Coverage of RMO No. 17-85 Regarding Jeopardy Assessment

BIR Ruling No. 195-85 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Nov 5, 1985

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November 5, 1985 BIR RULING NO. 195-85 295 (2) (a) 000-00 195-85 Gentlemen : This refers to your letter dated August 23, 1985, requesting clarification on the coverage of Revenue Memorandum Order No. 17-85 dated May 15, 1985. In reply, please be informed that regardless of the date of the deficiency income tax assessment against an individual, for as long as it involves 1981 and prior years, and it qualifies as a jeopardy assessment as this term is defined in the said Revenue Memorandum Order, the said deficiency assessment may upon request of the taxpayer be abated under Section 295(2)(a) of the Tax Code. cdta Very truly yours, (SGD.) TOMAS C. TOLEDO Acting Commissioner

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