Request of Taxpayers for Extension of Time for Investigation

October 21, 1964 REVENUE MEMORANDUM CIRCULAR NO. 46-64 SUBJECT : Request of Taxpayers for Extension of Time for Investigation TO : All Regional Directors, Chief Revenue Officers, Examiners and Others Concerned For record purposes and to preclude any charge of delayed action by the examiners on cases assigned to them for investigation and in relation to the provisions of Revenue Memorandum Order No. 43-64 dated July 3, 1964, the subject matter of which is to set a period of limitation for action on cases received, all examiners are hereby instructed to inform taxpayers requesting for extension of time within which they should be investigated, that they should submit their requests in writing stating specifically the reason or reason why they cannot be immediately investigated. A copy of the letter should be forwarded to the Chief Revenue Officer who will then take appropriate action on the said request. In this connection, the Chief Revenue Officer should determine whether the taxpayer is just delaying his investigation or trying to avoid the payment of taxes due from him, in which case the said request should be denied and if warranted by the circumstances of the case, the provisions of Section 15 of the National Internal Revenue Code should be applied. Examiners who cannot comply with the requirements of Revenue Memorandum Order No. 43-64 to report tax cases assigned to them within one hundred twenty (120) days from the issuance of the authority to investigate and the reason for non-compliance is the request of taxpayers for deferment of investigation should attach the letter from taxpayer in their request for revalidation of the authority to investigate. Strict compliance with the provisions of this Memorandum Order is hereby enjoined. aisadc (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue