TO

THRU

LETTER-REPLY

Dear Gentlemen and Madame:

This has reference to your letters, First Letter Request dated _____________ and
Second and Final Letter Request dated

An assessment must be made within three (3) years from the last day prescribed by law for
the filing of the tax return, for the tax that is being subjected to assessment or from the day
the return was filed, if filed late.

Assessments means by issuing the FLD/FAN.

We understand that LA is not an assessment. However, LA is the first step of the audit
examination process. Assessment is generally the result of the examination. Hence, even if the
assessment be made or issued today, it is already beyond 3 years.