REVENUE MEMORANDUM ORDER NO. 2-2008


SUBJECT : Delegation of Authority to Issue and Sign “Subpoena Duces Tecum” in Relation to the Conduct of Investigation on Taxpayer’s Accounting Records.

TO : All Revenue Officials, Employees and Others Concerned.

I. OBJECTIVE. - This Order is issued to identify revenue official authorized to sign in the “Subpoena Duces Tecum” (SDT) to facilitate the immediate assessment and collection of possible deficiency taxes that can be uncovered in the conduct of investigation on taxpayer’s accounting records.

II. COVERAGE. - SDT covered under this order shall be those related to the conduct of investigation pursuant to a Letter of Authority/Tax Verification Notice/Mission Order and shall not cover cases already filed in court.

III. POLICIES

For control and monitoring purposes, the following revenue officials are hereby authorized to issue SDT, to wit:

1. National Office

a. The Assistant Commissioner, Legal Service, or the

b. Concerned Head Revenue Executive Assistant (HREA) of Legal Service and Large Taxpayers Service, or the

c. Chief of the concerned Large Taxpayers Audit Division/District Office as may be specifically authorized in writing by the Commissioner.

2. Regional Office

a. Director, or in his absence, the Assistant Director, or the

b. Chief, Legal Division or the concerned Revenue District Officer, as may be authorized by the Regional Director thru a Regional Delegation Order.

This does not, however, preclude the Commissioner and Deputy Commissioners to exercise their authority under the National Internal Revenue Code to issue SDT in appropriate cases.

IV. REPEALING CLAUSE. - All orders and other issuances inconsistent herewith are modified accordingly.

V. EFFECTIVITY. - This Revenue Memorandum Order shall take effect immediately.

(Original Signed)
LILIAN B. HEFTI
Commissioner of Internal Revenue

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