DURING this time in which the Bureau of Internal Revenue is aggressive in handing out letters of authority left and right, it is important for taxpayers to know the due process when it comes to such deficiency tax assessments for them to avail the remedies provided by the law. The Court of Tax Appeals (CTA) en banc (EB) case illustrated here clarifies the 180-day period referred to in Section 228 of the Tax Code.

Thus, if a taxpayer files an administrative appeal to request the reconsideration of the decision of the CIR's duly authorized representative on a protest, the CIR is not given a fresh or separate 180-day period to decide on the administrative appeal.