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Informal PAN1 Option

Conference (Reply to PAN NO REPLY - Taxpayer “In Default”


(30 day period) or not)

Formal Letter of
Demand/Final
Reply within Assessment
Reply to PAN 15 days2
15 days Notice (FLD/FAN)3

(If Assessed by CIR’s Duly Authorized Representative) (If Assessed by CIR)


30 days 30 days

CIR’S DULY AUTHORIZED CIR ACTUAL


REPRESENTATIVE
PROTEST4
PROTEST (if Assessed by CIR)5
(Plus 60 days for
-or-
Supporting
Administrative Appeal (if Assessed by
Documents if
CIR’s Duly Authorized Representative)
Reinvestigation)

Inaction With Inaction With


180 days Decision 180 days Decision

Final Decision on Final Decision on


Option a Disputed Option a Disputed
(Appeal or Assessment (Appeal or Await Decision Assessment
Wait) (FDDA)3 Wait) (FDDA)3

Appeal within
Await
30 days from
Decision
180 days inaction Appeal within
30 days from
180 days inaction

Decision3
(Without Remedy Request for
Appeal within Option Appeal within Option
of Appeal Reconsideration
Appeal to CTA 30 days (Appeal to CTA Appeal to CTA 30 days (Appeal or
to CTA) 30 days from
from Denial or CIR) from Denial MR)
Receipt of Denial Motion for
Reconsideration

Motion for
Decision3 Reconsideration
1
Shall show in detail the facts and the law, rules and regulations, or jurisprudence on which the proposed assessment is based (Does not toll 30
2 An FDL/FAN issued beyond 15 days from filing of response to PAN valid if issued within the period of limitation to assess internal revenue taxes day period to
3
Shall state the facts, the law, rules and regulations, or jurisprudence on which it is based; otherwise, the assessment shall be void
Appeal to CTA)
4
Either a Request for Reconsideration (based on existing records; may involve questions of fact, law or both) or
Request for Reinvestigation (based on newly discovered or additional evidence; may involve questions of fact, law or both)
5
Request for Reconsideration only BJS

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