Submission of Report on Tax Cases Before the Expiration of the Period of Limitation on Assessment

May 9, 1980 REVENUE MEMORANDUM ORDER NO. 16-80 SUBJECT : Submission of Report on Tax Cases Before the Expiration of the Period of Limitation on Assessment TO : All Internal Revenue Officers, Employees and Others Concerned In order to forestall haphazard processing, review and assessment of taxes which are about to prescribe, the following order is hereby promulgated for the guidance of all concerned: 1. Field and office audit reports relative to internal revenue cases (income, business, transfer, etc.) should be submitted to the Regional Director and/or Assistant Commissioners not later than five (5) months before the prescription date, e.g. a) 1975 income tax returns of fixed and mixed income taxpayers should be submitted on or before October 15 and November 15, 1980, respectively; b) All other tax cases are to be reported not later than five (5) months before the 5th year after the return was filed and in the case of quarterly business tax returns, not later than five (5) months before the 5th year or 20th quarter after the return has been filed. 2. Under no circumstance should tax cases for field and office audit investigation be assigned to any examiner or investigating officer until and unless he has terminated tax cases about to prescribe. 3. "Jeopardy or table assessment" should never be resorted to and reports of investigation should be supported by documentary evidences and authorities; and acd 4. In all cases wherein the taxpayer concerned has signed a waiver of the period of prescription, with respect to a tax case about to prescribe, the report thereof should be submitted within three (3) months before the expiration of the period of prescription. All concerned is enjoined to comply strictly with this Order. (SGD.) RUBEN B. ANCHETA Acting Commissioner TAN A5329-J1139-A-0