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Question
NovaTech Holdings, a corporation with principal office in Pasig City, receives a Letter of Authority (LOA) dated March 12, 2026 from the Commissioner authorizing Revenue Officer Rosa Dizon to examine NovaTech's books for calendar years 2022 and 2023, to be conducted at NovaTech's premises. The LOA (i) authorizes entry and inspection of the books, ledgers, invoices, payroll records, and other pertinent records; (ii) directs NovaTech and its officers to produce the books and records; and (iii) instructs Summit Bank, the custodian of NovaTech's bank statements and related records, to cooperate and to produce the bank statements for the same period. The LOA lists Summit Bank as custodian and does not name any other banks. It does not specify the exact number of years beyond 2023 and is served on NovaTech's Chief Financial Officer on March 15, 2026. On March 20, 2026, Summit Bank refused to release the bank statements, citing Bank Secrecy Law (RA 1405) and asserting that the LOA does not explicitly authorize the bank to disclose the records without a court order. The Revenue Officer contends that the LOA’s language “bank statements and related records” is sufficient to include the bank records, and that the LOA is a valid instrument directing bank cooperation. (a)Identify the controlling doctrine or principle that governs the validity and scope of a Letter of Authority in tax examinations. (b)Determine, on these facts, whether the LOA covers the requested bank statements and whether Summit Bank must release them without a court order. (c)If the LOA is defective for lack of precise scope, explain the remedy for NovaTech and the likely impact on the audit and any resulting assessments.