RMO No. 23-2022 Digest

RMO No. 23-2022 (issued April 27, 2022) prescribes the standard numbering format for deficiency tax assessment notices pursuant to RR No. 12-99, as amended, and RMC No. 3-2022. Assessment notices for deficiency basic tax, surcharge and interest (Part I) and for compromise penalties (Part II), with the attached Details of Discrepancies, are issued in triplicate (taxpayer's copy, case docket copy, and approving office file copy). The Preliminary Assessment Notice (PAN) follows a uniform 43-character numbering system combining the LA Serial Number, Audit Case Number and a sequence number that resets to '00001' at the start of each year; the FLD/FAN uses the same combination with the prefix 'F' instead of 'P' (with FANs on BIR Form No. 0401 adding a tax type code), and the FDDA uses the prefix 'D'. Decisions on protests to the FLD/FAN are communicated through a FDDA together with a FAN bearing the amended assessment, and the protested FAN must first be cancelled. If a case is reassigned and a replacement eLA is issued, the letter of demand/assessment notice bears the recent LA Serial Number and Audit Case Number.