Please be informed that the herein taxpayer is availing Section 228 of Republic Act

8424, as amended otherwise known as the National Internal Revenue Code of 1997,
and Section 3.1.4 of Revenue Regulations 18-2013, herein quoted the applicable
provisions, to wit:

“SEC. 228. Protesting of Assessment. - When the Commissioner or his duly

authorized representative finds that proper taxes should be assessed, he shall first
notify the taxpayer of his findings x x x

x x x Within a period to be prescribed by implementing rules and regulations, the

taxpayer shall be required to respond to said notice. If the taxpayer fails to respond,
the Commissioner or his duly authorized representative shall issue an assessment
based on his findings. x x x”

Regional Director
Bureau of Internal Revenue
Revenue Region

Sir/Madame;

This refers to the Preliminary Assessment Notice received by this Corporation

on __________________, informing hereof of the deficiency Income tax, Value
Added Tax, Expanded Withholding Tax for the Taxable Year 2014.

apter, P. R., & Inaneditedvolume, J. C. (2001). Scientific research papers provide

evidence of frustration with giant style manuals. In P. Z. Wildlifeconservation, R.
Dawkins, & J. H. Dennett (Eds.), Research papers are hard work but boy are they
good for you (pp. 123-256). New York, NY: Simon & Schuster.
Qosenberg, Morris. (1994, September 11). This is how you cite an online news
article that has an author. The Washington Post. Retrieved from
http://www.washingtonpost.com/dir/subdir/2014/05/11/a-d9-11e3_story.html
* On p. 189, the 6th ed. manual says “We recommend that when DOIs are available,
you include them”—so you can skip the DOI if you can’t find it. Footnotes

determined that there exists sufficient basis to assess the taxpayer for any
deficiency tax or taxes, the said Office shall issue to the taxpayer a Preliminary
Assessment Notice (PAN) for the proposed assessment. It shall show in detail the
facts and the law, rules and regulations, or jurisprudence on which the proposed
assessment is based
If the taxpayer fails to respond within fifteen (15) days from date of receipt of the
PAN, he shall be considered in default, in which case, a Formal Letter of Demand
and Final Assessment Notice (FLD/FAN) shall be issued calling for payment of the
taxpayer's deficiency tax liability, inclusive of the applicable penalties.”

by submitting its response and disagreement to the aforementioned Preliminary

Assessment Notice, as follows:

I. DEFICIENCY INCOME TAX

Disallowed Expenses due to non-withholding

Income Not Subjected to VAT”, with no explanation to fully appraise the undersigned
of the facts and circumstances regarding the alleged deficiency.
“Sec. 2.58.5. Requirements for Deductibility. - An income payment which is
otherwise deductible under the Code shall be allowed as a deduction from the
payor's gross income only if it is shown that the income tax required to be withheld
has been paid to the Bureau in accordance with Secs. 57 and 58 of the Code.

A deduction will also be allowed in the following cases where no withholding

of tax as made:

(B) The recipient/payee failed to report the income on the due date thereof,
but the withholding agent/taxpayer pays the tax, including the interest incident to the
failure to withhold the tax and surcharges if applicable, at the time of
audit/investigation or reinvestigation/reconsideration.”

3.1 Mode of procedure in the issuance of a deficiency tax assessment:

3.1.1 Preliminary Assessment Notice (PAN). — If after review and evaluation by the
Commissioner or his duly authorized
VALUE ADDED TAX

Other income not subjected to VAT, P480,000.00

The aforementioned Value Added Tax out of the line in the Preliminary
Assessment Pan as merely “Other Income Not Subjected to VAT - P480,000.00, is
in contravention of Section 228 of the National Internal Revenue Code quoted as
follows:

“SEC. 228. Protesting of Assessment. x x x

x x xThe taxpayers shall be informed in writing of the law and the facts on which the
assessment is made; otherwise, the assessment shall be void.”

It is clear in the foregoing that the assessment is without legal nor factual

<Your name>
<Address>
<Address>

<Date>

<Debtor’s name>
<Title>
<Address>
<Address>
Dear <Debtor’s name>

Letter of demand – outstanding payment

I am writing in reference to <details of contract or agreement> and payment not

being received.
I enclose <specify the titles of the documents you are attaching, such as invoice
number and an original quote> dated <insert date> for the outstanding amount of
$ <amount>.
I demand full payment of the outstanding amount within <usually 14 days from the
date of this letter – best to specify the date>.
<Optional> Alternatively, and without prejudice to my rights for full recovery of the
debt, I am prepared to:
<Choose the option which is most appropriate>
 Accept the amount of $ <less than full payment> as full and final settlement of the
debt if paid within 7 days <or other appropriate period> from the date of this
letter.
<OR>
 Accept instalments of $<amount> per <week/month> until the debt is fully paid,
the first instalment to be paid on <date> and thereafter on the first working day of
every <week/month> until the debt is fully paid.
If this matter is not resolved by the time specified above, I reserve the right to
commence legal proceedings to recover the debt without further notice to you and
this letter may be tendered in court as evidence of your failure to pay. Legal action
may result in you having to pay legal costs, interest and could impact on your credit
history.
Should you wish to contact me to discuss, my telephone number is <insert number>.
Yours sincerely,

<Your name>