REVENUE REGULATIONS NO. 13-2001 issued October 10, 2001 implements certain provisions of the Tax Code regarding the authority of the Commissioner of Internal Revenue to abate or cancel tax liabilities of taxpayers based on any of the following grounds: 1) the tax or any portion thereof appears to be unjustly or excessively assessed; or 2) the administration and collection costs involved do not justify the collection of the amount due. Disputed assessments, including those which are void from the beginning, are not covered by the Regulations. The instances wherein penalties and/or interest imposed on a taxpayer may be abated or cancelled on the ground that the imposition thereof is unjust or excessive include the following: 1) filing of the return/payment of the tax is made at the wrong venue; 2) taxpayer’s mistake in payment of his tax is due to erroneous written official advice of a revenue officer; 3) taxpayer fails to file the return and pay the tax on time due to substantial losses from prolonged labor dispute, force majeure and legitimate business reverses; 4) assessment is brought about or the result of taxpayer’s non-compliance with the law due to difficult interpretation of the said law; 5) taxpayer fails to file the return and pay the correct tax on time due to circumstances beyond his control; and 6) late payment of the tax under meritorious circumstances specified in the Regulations. Abatement or cancellation of penalties on the ground that the administration and collection costs are more than the amount sought to be collected may be considered under the following instances: 1) assessment confirmed by lower court but appealed by the taxpayer to a higher court; 2) withholding tax assessment or delayed installment payment under meritorious circumstances; 3) assessment reduced after reinvestigation, but taxpayer is still contesting reduced assessment; and 4) such other instances which the Commissioner may deem analogous to the aforecited instances. The authority of the Commissioner to abate or cancel tax liabilities is generally applicable to surcharge and compromise penalties only. However, in meritorious instances, the Commissioner may likewise abate the interest as well as the basic assessed tax, provided, however, that cases for the said abatement or cancellation shall be coursed through the Deputy Commissioners for Operations Group and Legal and Inspection Group.