COMMISSIONER OF INTERNAL REVENUE

Petitioner,

GEORGE A. TALAMAYAN
Respondent

CTA OC No. 021

Second Division
December 3, 2019

FACTS
On October 8, 2009, Regional Director of Revenue Region No. 2, issued letter
of Letter of Authority (LOA), authorizing Revenue Officer Christy B. Daytec
(RO Daytec) RDO No.9, La Trinidad, Benguet, to examine defendant’s books
of accounts and other accounting records for the period of January 1, 2008 –
December 31, 2008.

RO Daytec issued two subsequent Request for Presentation of Records, RDO

Teogenes T. Abrigo of RDO No.9 issued the Final Request for Presentation
of Records with the warning that the failure to comply with the above
request would result in the issuance of a subpoena duces tecum.

On June 15, 2011, defendant received Subpoena Duces Tecum issued by OIC-
Regional Director, Eduardo T. Bajador of Revenue Region No. 2