Letter Notice (LN) Disqualifies Amending Returns

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Since the law specifically requires an LOA and RMO 32-2005 requires conversion of the previously issued LN to an LOA, the absence thereof cannot be swift under the rug, as the CIR would have it.  In fact Revenue Memorandum Circular No. 40-2003 considers an LN as a notice of audit or investigation only for the purpose of disqualifying the taxpayer from amending this returns.