In one case where a taxpayer denied having received the tax assessment notice, the SC

declared that, in proving the taxpayer’s receipt of notice, the BIR could have simply presented
the registry receipt or the certification from the postmaster that it mailed the notice (CIR vs.
Metro Star Superama, Inc., G. R. No. 185371 dated 8 December 2010). Having failed to do so
made the entire assessment process void.

In a recent Court of Tax Appeals (CTA) case (Republic of the Philippines vs. Molinar, doing
business under the name “Romac Marketing”, CTA OC No. 14 dated 6 June 2014), the
taxpayer similarly claimed that the BIR failed to give him due notice of the tax assessment
against him. However, the CTA found that there was due process after the BIR presented the
registry receipts of the Letter Notice and Second Notice and the registry return receipts of the
Amended Preliminary Assessment Notice (PAN) and the Formal Letter of Demand (FLD) and
Final Assessment Notice (FAN), in addition to presenting revenue officers who prepared and
mailed the notices.