The Waiver of Statute of Limitations must indicate the date of execution by the taxpayer and the date of acceptance by the Commissioner of Internal Revenue (CIR) to be valid and effective as prescribed by RMO No. 20-90.

The taxpayer, through its Controller, executed two "Waivers of the Defense of Prescription" under the Statute of Limitations of the National Internal Revenue Code (NIRC). These documents were accepted by Revenue District Officer, who failed to indicate his date of acceptance. The Court ruled that the waivers were defective and could not validly extend the original three-year prescriptive period wherein the CIR may assess the taxpayer. The date of acceptance must be indicated to determine whether the waiver was validly accepted before the expiration of the original three-year period. If the acceptance was made beyond the prescriptive period, the waiver is defective and cannot validly extend the original three-year period for the respondent to issue an assessment. (East Asia Power Resources Corporation vs. Commissioner of Internal Revenue, CTA Case No. 7956, December 26, 2011)