SOME taxpayers may have experienced preparing and submitting extensive documents to the Bureau of Internal Revenue (BIR) to challenge a deficiency tax assessment, only to have their arguments and evidence ignored. In such cases, they often turn to the Court of Tax Appeals (CTA), as some BIR officers merely reiterate the initial findings in their Preliminary Assessment Notice (PAN) in the Final Assessment Notice (FAN) and Final Decision on Disputed Assessment without addressing the taxpayer's evidence or explaining why the assessment was upheld.

Fortunately, the CTA, both in division and en banc, has rendered several decisions stating that it violates a taxpayer's right to due process when BIR officers render similar decisions in the resolution of a reply to PAN and protest to a FAN without explaining why the taxpayer's arguments were rejected. Tax assessments issued in such cases, where due process is ignored, are deemed null and void.