Barcelon, Roxas Securities Inc. v CIR; G.R. No. 157064; 07 Aug 2006
FACTS: After an audit investigation conducted by the BIR, respondent Commissioner issued an assessment for deficiency income tax arising from the disallowance of the item on salaries, bonuses and allowances as part of the deductible business expense since petitioner failed to subject the same to withholding taxes. This assessment was covered by a Formal Assessment Notice dated 01 February 1991 which, respondent alleges, was sent to petitioner through registered mail on 06 February 1991. ISSUE(S): Whether or not respondent’s right to assess and collect petitioner’s alleged deficiency income tax is barred by prescription. HELD: YES. An assessment is made within…