After examining the books and records of EDS Corporation, the 2004 final assessment notice, showing basic tax of P1,000,000, deficiency interest of P400,000, and due date for payment of April 30, 2007, but without the demand letter, was mailed and released by the BIR on April 15, 2007. The registered letter, containing the tax assessment, was received by the EDS Corporation on April 25, 2007.
a) What is an assessment notice? What are the requisites of a valid assessment? Explain. (3%)
b) As tax lawyer of EDS Corporation, what legal defense(s) would you raise against the assessment? Explain. (3%)
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