Under Section 204 of RA 7160 and existing jurisprudence, real property is appraised based on its actual use . Since the property is being used exclusively for residential purposes, classifying it as Commercial is legally erroneous.
You must explicitly state if you are seeking reconsideration (re-evaluation of current records) or reinvestigation (submission of new evidence). sample protest letter tax assessment philippines
The BIR failed to issue a Preliminary Assessment Notice (PAN) prior to the issuance of the FLD, which is a mandatory requirement under Section 228 of the NIRC of 1997, as amended. Consequently, I was deprived of the opportunity to respond to the initial findings. Under Section 204 of RA 7160 and existing
No Preliminary Assessment Notice (PAN) was issued before this Formal Assessment Notice, in violation of Section 228 of the NIRC and Revenue Regulations No. 12-99. A PAN is mandatory for deficiency assessments except in cases of fraud or failure to file a return, neither of which exists here. Hence, the formal assessment is void ab initio. The BIR failed to issue a Preliminary Assessment
Note: This is a general guide. For complex cases, consult a tax lawyer or CPA.
[Explain why the BIR's finding is incorrect, providing evidence like missing tax credits or erroneous expense disallowance].
: You must specify the laws, rules, or jurisprudence (court decisions) supporting your dispute for every item in the assessment. General or vague denials are not sufficient.