An assessment must be sent to and received by a taxpayer, and must demand payment of
taxes described therein within a specific period. In other words, assessment is a notice to the
effect that the amount therein stated is due as a tax and a demand for the payment thereof. It
fixes and determines the tax liability of a taxpayer. In the Audit Result/Assessment Notice in this
case, there is no indicia of any due dates. The due dates in the assessment notices were left
blank. Thus, in effect, the FAN does not amount to a formal demand but a mere request for
payment. For lack of a definite and unequivocal demand for payment of a certain date and for
want of due process, the assessment is void. (Commissioner of Internal Revenue vs. Fitness
By Design, Inc. CTA EB No. 970, July 14, 2014)
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