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    Letter Response - Request For ELOA Revalidation V2

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    Jazz Tracey
    The law firm Tayag & Associates wrote a letter on behalf of their client to request the revalidation of an Electronic Letter of Authority (E-LOA) issued more than 120 days ago relating to a tax audit. They explained that more than 120 days had passed since receiving the E-LOA without any notice or report from the audit investigation. Citing legal precedent, they noted that revenue officers must submit a final report or progress report and surrender the letter for revalidation if the audit cannot be completed within 120 days. Considering pandemic lockdowns that occurred after the E-LOA was received, they understood the delay but clarified their client did not waive or extend the audit period. The letter requested revalidation of

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    Letter Response - Request For ELOA Revalidation V2

    Uploaded by

    Jazz Tracey
    403 views2 pages
    The law firm Tayag & Associates wrote a letter on behalf of their client to request the revalidation of an Electronic Letter of Authority (E-LOA) issued more than 120 days ago relating to a tax audit. They explained that more than 120 days had passed since receiving the E-LOA without any notice or report from the audit investigation. Citing legal precedent, they noted that revenue officers must submit a final report or progress report and surrender the letter for revalidation if the audit cannot be completed within 120 days. Considering pandemic lockdowns that occurred after the E-LOA was received, they understood the delay but clarified their client did not waive or extend the audit period. The letter requested revalidation of

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    Letter Response - request for ELOA revalidation V2

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    The law firm Tayag & Associates wrote a letter on behalf of their client to request the revalidation of an Electronic Letter of Authority (E-LOA) issued more than 120 days ago relating to a tax audit. They explained that more than 120 days had passed since receiving the E-LOA without any notice or report from the audit investigation. Citing legal precedent, they noted that revenue officers must submit a final report or progress report and surrender the letter for revalidation if the audit cannot be completed within 120 days. Considering pandemic lockdowns that occurred after the E-LOA was received, they understood the delay but clarified their client did not waive or extend the audit period. The letter requested revalidation of

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    403 views2 pages

    Letter Response - Request For ELOA Revalidation V2

    Uploaded by

    Jazz Tracey
    The law firm Tayag & Associates wrote a letter on behalf of their client to request the revalidation of an Electronic Letter of Authority (E-LOA) issued more than 120 days ago relating to a tax audit. They explained that more than 120 days had passed since receiving the E-LOA without any notice or report from the audit investigation. Citing legal precedent, they noted that revenue officers must submit a final report or progress report and surrender the letter for revalidation if the audit cannot be completed within 120 days. Considering pandemic lockdowns that occurred after the E-LOA was received, they understood the delay but clarified their client did not waive or extend the audit period. The letter requested revalidation of

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    TAYAG & ASSOCIATES

    ATTORNEYS AT LAW

    __ July 2021

    __________________________
    Revenue District Officer, Las Piñas
    OHZ Building, Lot1, E-F, L. Hernandez Avenue,
    Brgy. Almanza Uno, Las Piñas City

    Subject: Last Opportunity Before Issuance of Sub-poena Duces Tecum


    dated in relation to E-Letter of Authority No. PUT ELOA
    NUMBER

    Gentlemen:

    We write in behalf of our Client regarding the abovementioned letter in relation to the E-
    Letter of Authority No. (“eLOA”) which our client received last 08 February 2021.

    In the E-LOA, it was specifically mentioned that the audit of our company will be
    conducted by the duly authorized and named therein representatives of Revenue District No. 53A
    – Las Piñas City. Since our Client received the eLOA, however, they have not received any
    notice or report regarding the audit investigation.

    As such, while we respectfully manifest our willingness to comply with the


    abovementioned audit investigation, may we respectfully call attention to the fact that it has been
    more than one hundred and twenty (120) days since we received the e-LOA and we submit that
    the E-LOA should be re-validated pursuant to RMO No. 38-88 and RMC No. 40-2006. The
    procedure and requirement for revalidation has been supported by rulings from the Court of Tax
    Appeals, such as the case of AFP General Insurance Corporation vs. Commissioner of Internal
    Revenue, thus:

    “A Revenue Officer (RO) is allowed only one hundred and twenty (120)
    days from the date of receipt of a Letter of Authority by the taxpayer to conduct
    the audit and submit the required report of investigation. If the RO is unable to
    submit his final report of investigation within the 120-day period, he must submit
    a progress report to his head of office and surrender the LA for revalidation.”

    Considering the resurgence of the COVID-19 pandemic the month after our Client’s
    receipt of the eLOA we understand that the lockdowns imposed last March and April 2021 may
    have severely impeded the conduct of the investigation procedures within the 120-day period
    necessitating its extension. Our client, however, has communicated to us that they have not
    signed any prior waiver or extension of this audit period.

    In view of the foregoing, we respectfully request for the revalidation of the E-LOA for
    purposes of proper documentation of the audit of our Client’s company. Thereafter, we will
    immediately communicate with the authorized representatives of the Revenue District No. 53A –
    TAYAG & ASSOCIATES
    ATTORNEYS AT LAW

    Las Piñas City as indicated in the revalidated eLOA for the examination and/submission of our
    accounts and documents.

    We hope that this letter and our Client’s request for the revalidation of the E-LOA would
    merit the prompt action of your good office. Rest assured our Client will immediately and strictly
    comply with the E-LOA upon its revalidation.

    Very truly yours,

    TAYAG AND ASSOCIATES

    By:

    Received by: ______________ Date: _______________

    Served by: ________________ Date: _______________


    Witness: ______________________________________

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