REVENUE MEMORANDUM ORDER NO. 56-2022 issued on December 16, 2022
amends certain provisions of Revenue Memorandum Order (RMO) No. 23-2022,
prescribing the standard format in the numbering of deficiency tax assessment
notices pursuant to Revenue Regulations (RR) No. 12-99, as amended, and
Revenue Memorandum Circular (RMC) No. 3-2022.
Item No. II.4 of RMO No. 23-2022 is hereby amended to delete the quoted
provision hereunder:
“xxx… together with the FAN bearing the amended
deficiency tax assessment. However, to effect the issuance of
the FFDA/FAN, the protested FAN shall first be cancelled.”
Thus, the issuance of Final Decision on Disputed Assessment (FDDA)
shall no longer be accompanied by an amended Final Assessment Notice (FAN)
and the manner of issuance of FDDA pursuant to RR No. 12-99, as amended,
shall be maintained.
The hyphen character “-” in the numbering scheme prescribed thereat,
separating the Correspondence Type Code (e.g., “P” for PAN), LA Serial Number,
Audit Case Number, and Sequence Number shall be replaced with the vertical
bar symbol “|”. The LA Serial Number shall now include the alpha characters “eLA”
as shown below:
P | eLA000000000000 |
000000-0000-0000-
000000 | 00000
Correspondence LA Serial Number Audit Case Number Sequence
Type Code Number
Effective January 1, 2023, where the Sequence Number shall reset to start
again at “00001”, the assignment of this number to a specific assessment notice
shall now be based on the count of the correspondence type issued per issuing
office. This means that the sequence number in the PAN issued for Case A might
be different from the sequence number to be assigned in the succeeding
assessment notices such as FLD/FAN or FFDA, if such case reaches this level.
Offices which are already using the Internal Revenue Integrated System –
Case Management System-Audit (IRIS-CMS-A) module may still use the
generated correspondences in the said system and send the same “as is” to
concerned taxpayer or edit the document reference number reflected therein to
indicate the prescribed numbering scheme.
For cases which were created in the Electronic Letter of Authority System
(eLAMS), the prescribed numbering scheme must be applied considering that the
generation of correspondence is outside of the said system.
Any assessment notice issued which reference number is not in
accordance with the prescribed numbering scheme shall not render the issued
tax assessment notice invalid for as long as the basic requisites such as the
factual and legal basis, and details of tax assessments have been indicated.