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What tax accounting titles should you include in your chart of accounts?

0 Views· 11/26/23
Aryel Narvasa
Aryel Narvasa
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Whether the failure and refusal and continued failure and refusal of revenue officers involved to review, sign and release the Acceptance Payment Form (APF) and/or Certificate of Tax Delinquencies/Tax Liabilities (CTD) shall legally construed to be an APPROVAL of APF and/or CTD.
Whether the AGREEMENT FORM showing my unpaid basic improperly accumulated earning tax, surcharge, compromise penalty and delinquency interest and the approving signatures of the authorised representative of the BIR Chief and the taxpayer cannot be considered a relevant documentation of being delinquent.
Whether the BIR Form No. 0605 showing my unpaid basic improperly accumulated earning tax, surcharge, compromise penalty and delinquency interest and the approving signatures of the authorised representative of the BIR Chief and the taxpayer cannot be considered a relevant documentation of being delinquent.
Whether the failure and refusal and continued failure and refusal of the revenue officers involved to prepare, sign and issue the required Notice of Issuance of Authority to Cancel Assessment (with or without an amount thereof) within 15 days upon receipt of my AFP and TAR shall automatically make the same FINAL AND IRREVOCABLE.
WHAT I UNDERSTAND.
By estoppel and/or thru RA 11032, the request for license, permit, signature, certificate, availment and the likes is DEEMED APPROVED if the grace period to deny the same had already expired or prescribed.
Further, my action is based on the spirit of Republic Act (RA) No. 11213 which says that after the lapse of 15 days from submission of Acceptance Payment Form (APF) and the RDO knowingly failed and ignored to sign and return the same to the applicant-taxpayer, the same shall legally be considered deemed ‘APPROVED’. The pages where the spirit of RA 11213 is written are presented in the next pages.
Hence, if my APF (BIR Form No. 0621-DA) is deemed “approved”, the Certificate of Tax Delinquencies/Tax Liabilities (CTD) is also deemed “approved” for the very reason that per RR 4-2019 the APF (step 2) precedes CTD (step 1). Its snippet is presented below.
Accordingly, the BIR Chief’s authorised representatives or the revenue officers involved knowingly failed and refused and continued to fail and refuse to render a relevant resolution to my TAR until the receipt of their twin BIR letters on August 10, 2019. Meaning, my AFP and TAR are already FINAL AND IRREVOCABLE. The snippet of Section 20, RA 11213 which is applicable to and being invoke to be used in my case and is presented below.

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