CIR vs BASF Coating + Inks Phil., Inc.; G.R. No. 198677; 26 Nov 2014

in Legal Chyme by

Respondent, after its dissolution, moved out of its address in Las Piñas City and transferred to Laguna. It submitted various documents among which is BIR Form No. 1905, which refers to an update of information contained in its tax registration.

At various times, BIR officials conducted examination and investigation of respondent’s tax liabilities at the latter’s new address in Laguna. The BIR also sent respondent a letter informing it of the results of their investigation and inviting it to an informal conference. It, however, sent by registered mail a Formal Assessment Notice (FAN) for deficiency taxes to respondent’s former address in Las Piñas.

Whether or not respondent’s change of address tolled the running of the statute of limitations.

NO. Petitioner, by all indications, is well aware that respondent had moved to its new address in Laguna. Despite the absence of a formal written notice of respondent’s change of address, the fact remains that petitioner became aware of respondent’s new address as shown by documents replete in its records. As a consequence, the running of the three-year period to assess respondent was not suspended and has already prescribed.

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