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MEMORANDUM
This refers to taxpayer JUAN DELA CRUZ, against whom prima facie evidence of tax fraud was
discovered during the conduct of a preliminary investigation by the Special Investigation Division of that
Region.
In this regard, it has been decided by the Commissioner of Internal Revenue, based upon the
recommendation of the Deputy Commissioner, Legal and Inspection Group, that an audit / investigation
for tax fraud shall be conducted by the SID on the tax liabilities of the aforesaid taxpayer, for the taxable
period CYs 2006-2007.
It is hereby requested that the records of Revenue District No. 8, Baguio City, where the taxpayer
is registered, be reviewed, to determine if any Letter of Authority (LA) was issued to the taxpayer covering
the same taxable period. In the event that no LA has yet been issued to the taxpayer for the aforesaid
taxable period, the Revenue District Office (RDO) is hereby advised that it is precluded from issuing an
LA for the taxpayer, covering the said taxable period.
If, however, an LA was issued, the same shall be considered as automatically cancelled and
invalid, effective on _____________, and the Revenue Officer(s) assigned must therefore cease all
activity attendant to the conduct of any audit / investigation under the cancelled LA. Likewise, the RDO
must, within five (5) days from receipt of this Memorandum:
Inform the concerned taxpayer of the cancellation of the LA issued by that Office; the change
of audit jurisdiction from the RDO to the SID; and the forthcoming issuance of the
corresponding LA covering the tax fraud audit / investigation, using the format prescribed in
Revenue Memorandum Order No. 5-2009; and
Transmit to the National Investigation Division the entire docket of the case, for integration
with existing documents thereat.