City of Makati received assessment notices imposing deficiency taxes in the amount of 1.3B for the years 1999-2002.

Makati, however, protested. BIR, on its part, said that the assessments against Makati were already final and executory. Makati, nonetheless, requested for another reinvestigation. Revenue officer and a deputy commissioner granted the request. Meetings were thereafter made between Makati and the Secretary of Finance, and BIR officials for the reconciliation of the records and positions of Makati and the BIR and Makati offered compromise settlement of the tax liabilities for 1999-2001. Pursuant to the compromise settlement, Makati paid P100M in payment of the taxes due for 1999-2001. Makati, thereafter, offered compromise settlement of the taxes due for 2002-2004 but BIR denied, and issued tax assessments anew against Makati. BIR said that Makati is still liable for deficiency taxes for the taxable years 1999-2001, and 2002-2004. Makati protested. CIR denied. Makati then filed a Petition for Review with the CTA. ISSUE: WON the reinvestigation of the case reversed the finality of the assessments HELD: No Only the Commissioner of Internal Revenue has the power to reverse, revoke or modify any existing ruling of the Bureau of Internal Revenue (BIR), which power cannot be delegated. In assessment cases, a reopening/reinvestigation after a final decision on disputed assessment (FDDA) has been issued must be initiated by the commissioner. Otherwise, the reopening / reinvestigation is without authority and failure to appeal the FDDA to CTA would render the assessment final and executory. Here, the reinvestigation was merely granted by a revenue officer and a deputy commissioner.