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Issuance of a 10-day Preliminary Letter Constitutes Sufficient Compliance of Revenue Regulations No. 12-85

BIR Ruling No. 246-91 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Nov 12, 1991

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November 12, 1991 BIR RULING NO. 246-91 229 000-00 246-91 S i r : This refers to your letter dated September 30, 1991 requesting for an opinion as to whether a 10-day Preliminary Letter is sufficient compliance with Revenue Regulations No. 12-85; or whether both the Pre-Assessment Notice and the 10-day Preliminary Letter are required to be issued for purposes of issuing a formal demand/assessment notice. In reply, please be informed that a 10-day Preliminary Letter which was marked as "Annex A" in your letter has the same purpose as the Pre-Assessment Notice marked as "Annex B" also in said letter. In view of the foregoing, this Office believes, and so hold that the issuance of the 10-day Preliminary Letter constitutes sufficient compliance of Revenue Regulations No. 12-85; hence a subsequent issuance of a Pre-Assessment Notice is no longer needed for purposes of issuing a formal demand/assessment notice. Very truly yours, (SGD.) JOSE U. ONG Commissioner

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