REVENUE MEMORANDUM ORDER NO. 8-2006 issued on March 22, 2006 prescribes the
guidelines and procedures in the implementation of the Letter of Authority Monitoring System
All unused blank sets of LA forms in the custody of Large Taxpayers Audit and
Investigation Division (LTAID) I and II, Large Taxpayers District Office (LTDO), National
Investigation Division (NID), Revenue District Offices (RDOs), Special Investigation Division
(SID) and Regional/National Task Forces (TF) shall be surrendered to the Office of the Assistant
Commissioner – Large Taxpayers Service (OACIR-LTS)/OACIR – Enforcement Service
(ES)/Office of the Regional Director (ORD)/Project Manager (PM) upon roll-out of the LAMS.
The ACIR-LTS/ACIR-ES/Regional Director (RD)/PM shall be accountable and responsible for
requisition of blank LA forms from the Accountable Forms Division.
Under the LAMS, cases that have not been terminated shall be considered as “Open”
until a Termination Letter or a duly approved Tax Credit Certificate/Tax Refund Notice is issued
by the RD or the ACIR-Assessment Service (AS), as the case may be. For LAs whose taxpayers
cannot be located, they shall be classified as “Cancelled” rather than “Closed”. If the taxpayer is
transferred to another district and said taxpayer has an “Open” audit case, the case status in the
said district shall be cancelled and the docket, if any, should be transmitted to the new RDO for
the continuance of audit under a newly issued LA (with a notation “This cancels LA No. ____” ).
Only one LA shall be issued to the same taxpayer, for the same tax type and period,
except where an LA was issued for a specific tax type only and subsequently, another LA was
issued to the same taxpayer by the same or another office covering the investigation of all
internal revenue taxes for the same taxable period. In case two or more LAs are issued to the
same taxpayer for the same tax type and for the same period, the power to decide which LA shall
prevail shall be under the exclusive jurisdiction of the Commissioner of Internal Revenue. The
LA prevailed upon shall be considered cancelled.
Where an LA had been previously issued for which deficiency taxes thereon had been
paid or assessed as reflected in the docket and corresponding report of investigation, no new LA
shall be issued for the same taxpayer covering the same tax type and taxable period, except in
fraud cases. Any payment of deficiency tax or any amount assessed on the first audit case shall
be credited against assessment in the subsequent fraud case if the findings/discrepancies in the
fraud investigation disclose the same findings or issues included in the first audit case.
In case the audit of cases covered by LAs cannot be completed within the prescribed
period, the Revenue Officer (RO) may request for revalidation of the LA. Only one revalidation
shall be allowed provided the RO shall render a progress report on the case duly noted by the
Group Supervisor and approved by the head of the investigating division/office.
For purposes of cross-referencing, TVNs issued on protested cases shall bear the notation
“Reinvestigation of the Tax Case per LA No. ________ dated _______”. Protested cases under
re-investigation shall not be assigned to the same RO who handled the original investigation.
Upon rollout of the LAMS, the OACIR-LTS/OACIR-ES/ORD shall encode data on LAs
issued from August 26, 2002, whether or not they have been signed, spoiled or cancelled. The
updating of the status of signed LAs shall be the responsibility of the issuing offices, including
“Open” or “Closed” cases no longer in their custody at the time of the issuance of this RMO.
For cases terminated or forwarded to any of the appropriate offices, the concerned issuing office
shall indicate the date of termination or transmittal, as the case may be. The concerned receiving
office shall validate the updates done by the issuing office. For this purpose, access shall be
given to the Records Division or the Administrative Division to validate updates of “Closed”
The manual “List and Status of LAs Issued” starting from LAs issued since August 26,
2002 shall be continued to be submitted to Audit Information and Tax Exemption and Incentives
Division, until such time that full confidence has been established on the LAMS.
The “List of Selected Taxpayers for Issuance of LA” shall be prepared manually by the
concerned issuing offices pending full implementation of the LAMS where the generation of the
LAs shall be automated. Once the LA issuance is fully automated, the “Data Entry” Module shall
cease to exist and the concerned issuing offices will simply key-in the required information on
the said “List” as appearing on the screen.