06/03/2026
๐๐๐ฟ๐ถ๐๐ฝ๐ฟ๐๐ฑ๐ฒ๐ป๐ฐ๐ฒ ๐จ๐ฝ๐ฑ๐ฎ๐๐ฒ | ๐๐ฆ๐ต๐ต๐ฆ๐ณ ๐ฐ๐ง ๐๐ถ๐ต๐ฉ๐ฐ๐ณ๐ช๐ต๐บ (๐๐๐)
A Letter of Authority (LOA) is not a general authority that allows any revenue officer to conduct an audit. It is a special authority issued only to the specific revenue officers named in the LOA.
๐ Key points to remember:
โ๏ธ Only the officers explicitly named in the LOA are authorized to conduct the audit.
โ๏ธ Substituting or reassigning officers without issuing a new LOA is improper.
โ๏ธ A Memorandum of Assignment (MOA) cannot replace or serve as proof of audit authority.
This doctrine reinforces that the power to authorize tax investigations belongs exclusively to the Commissioner of Internal Revenue or his duly authorized representative.
๐ Case Reference: The European Hair Factory, Inc. v. CIR
CTA Case No. 10534 | January 27, 2026
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