Flashcards Studio

Sunrise Industries, Inc., a VAT-registered taxpayer, receives a Final Assessment Notice (FAN) for the year 2023 indicating VAT deficiency of ₱4,200,000 arising from an input-output mismatch. The FAN states the tax type (VAT), the year (2023), the amount due, and the deficiency reason but omits a computation schedule or any supporting data. On the same day, the BIR issues a separate Collection Demand directing payment of ₱4,200,000 within 15 days; the Collection Demand states the tax type, the period (2023), and the amount due but expressly notes that the period and the basis are “consistent with FAN” and provides only a single-line computation instead of a full schedule. Five days later, the BIR levies Sunrise’s bank account to satisfy the amount. Sunrise challenges the levy as void for lack of essential requisites. (a)Identify the requisites of a valid final assessment under the NIRC and the requisites of a valid collection demand. (b)Distinguish, with brief rationale, the controlling rule that makes a levy valid when all requisites are present versus invalid when any requisite is missing. (c)Apply to the facts and determine whether the levy is proper, and outline Sunrise’s possible remedies.