Chico-Nazario

FACTS: Respondent on 21 April 1994 received a Preliminary Assessment Notice (PAN) dated 13 April 1994 for deficiency income tax. The following day, it received a Formal Assessment Notice (FAN). It protested against the FAN in two protest letters dated 06 May and 23 May 1994. In both letters, respondent requested for the cancellation of the tax assessment, which they alleged was invalid for lack of factual and legal basis. On 16 October 2002, respondent received from the CIR a Final Decision dated 08 October 2002 denying respondent’s protest against the FAN and affirming the same in toto. ISSUE(S): Whether or not…

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FACTS:On 10 October 1989, the BIR issued an assessment against petitioner finding the latter liable for deficiency documentary stamp tax (DST) on its 1985 sales of US currency to the Central Bank of the Philippines. Petitioner in a letter protested against the assessment, requesting for reconsideration. Petitioner did not receive any immediate reply to its protest letter. The BIR on 23 October 1992 served petitioner a Warrant of Distraint and/or Levy for the assessed deficiency DST for taxable year 1985. On 11 September 1997, respondent received a letter dated 13 August 1997 and signed by respondent denying petitioner’s request for…

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