Lumanta & Associates Law Office

March 18, 2021 BIR RULING NO. OT-079-21 Sec. 2 (r) of Revenue Bulletin No. 01-03; BIR Ruling No. 1387-2018 Lumanta & Associates Law Office Suite B, 2nd Floor, Overland Park Building No. 245 Banawe St. cor. Quezon Ave. Quezon City Attention: AAA and BBB Gentlemen : This refers to your letter dated February 04, 2019, requesting, on behalf of CCC , for cancellation of the Final Notice Before Seizure dated January 21, 2019 issued by Ms. Grace Evelyn A. Lacerna, Chief, Accounts Receivable Monitoring Division (ARMD), pursuant to Letter of Authority (LOA) No. __________ dated July 28, 2011, and cancellation and withdrawal of her Deficiency Income Tax Liabilities for taxable years 2003 and 2004. In reply, please be informed that requests for rulings on issues covered by an on-going collection proceeding is a "No Ruling Area" under Section 2 (r) of Revenue Bulletin (RB) No. 01-03 which provides, to wit: " SECTION 2. List of No-Ruling Areas. The following shall hereby be construed and identified as "No-Ruling Areas": xxx xxx xxx r) Issue/s or transactions involving directly or indirectly the same taxpayer/s which is/are the subject of an investigation, on-going audit, administrative protest, claim for refund or issuance of tax credit certificate, collection proceedings , or a judicial appeal subject to Section 3 hereunder . . ." (Emphasis and underscoring supplied) Thus, this Office declines to issue a definitive ruling on the issue raised. Please be guided accordingly. Very truly yours, (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue