Investigation, Assessment and Review of Tax Cases

August 11, 1964 REVENUE MEMORANDUM CIRCULAR NO. 28-64 TO : All Revenue Officers and Others Concerned SUBJECT : Investigation, Assessment and Review of Tax Cases For your immediate information and guidance, there is quoted below the observations of the Supreme Court in G.R. No. L-18007, entitled "Republic of the Philippines versus Benito H. Lopez", promulgated on March 30, 1963: "However, we feel it our duty to call attention to the extraordinary reduction by the revenue authorities of the taxes due in this case from the original P245,100.29 to less than one-tenth of it (P20,346.14) upon reinvestigation. Such a result is ample evidence that the first assessment was carelessly made, without regard to the true facts, and it strongly reflects upon the efficiency of the revenue examiner who made the grossly excessive assessment. Equally anomalous is the fact that after the taxpayer had promised to pay the computed tax, and after he had failed to keep his promise, the tax authorities should still agree to a further revision of the assessment. Irregularities of this kind inevitably provoke suspicion over the competency and honesty of the tax collecting operations, and it is expected that the competent authorities will take immediate and drastic steps to stop such deplorable practices." To preclude unwarranted suspicion as regards the competency and honesty of tax assessment and collection operations, and the repetition of future similar extra-ordinary reduction of taxes, it is henceforth desired that, all revenue officers who are primarily entrusted with the functions of investigation, assessment and review of tax cases, should exercise utmost diligence and prudent care in the performance of their official duties. LexLib Strict compliance herewith is enjoined. (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue APPROVED: (SGD.) ARMAND V. FABELLA Acting Secretary of Finance