NINTH DIVISION
[CA-G.R. SP NO. 77062. January 8, 2008.]
INTERVET PHILIPPINES, INC., petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, DAKILA FONACIER and REGIONAL DIRECTOR OSCAR L. SEVILLA, respondents.
D E C I S I O N
CRUZ, J p:
On June 11, 1998, Bureau of Internal Revenue (or "BIR") Regional Director Virginia L. Trinidad issued Letter of Authority (or "LOA") No. 170177 authorizing Revenue Officer Edwin T. Guzman of Revenue District Office No. 39, South Quezon City, to examine the books of accounts and other accounting records of Intervet Philippines, Inc. (or "petitioner") for all taxes, except VAT, for the period January 1, 1996 to December 31, 1996. To extend the period for assessment of the proper taxes, petitioner executed a Waiver of the Statute of Limitations on October 29, 1999. AECcTS
On November 15, 1999, Revenue District Officer Corazon Pangcog (or "Pangcog") invited petitioner to an informal conference on November 17, 1999 regarding the report of the investigation on its 1996 corporate tax return. In response, petitioner wrote to Pangcog requesting for additional information that would help it in analyzing its...
