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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE
BUREAU OF INTERNAL REVENUE

January 15, 2009

REVENUE MEMORANDUM ORDER NO. 3-2009

Subject : Amendment and Consolidation of the Guidelines in the Conduct of

Surveillance and Stock-Taking Activities, and the Implementation of the
Administrative Sanction of Suspension and Temporary Closure of
Business.

To : All Internal Revenue Officers and Others Concerned.

I. BACKGROUND

While taxpayer education and tax information campaigns have done much to
increase taxpayer awareness, the role of enforcement in enhancing revenues and
promoting greater voluntary compliance is of equal significance in effective tax
administration.

In this regard, the BIR shall endeavor to intensify certain aspects of its
enforcement operations through Oplan Kandado, an initiative involving the
strengthening of the Bureaus imposition of prescribed administrative sanctions for non-
compliance with such essential requirements as: the issuance of receipts, filing of returns,
declaration of taxable transactions, taxpayer registration, and paying the correct amount
of taxes as mandated by the norms / standards of their particular industry or line of
business.

II. OBJECTIVE

This Order is being issued to:

1. Amend and consolidate the policies, guidelines and procedures to be

observed in the conduct of surveillance operations and the enforcement of
the administrative sanction of suspension and temporary closure of
business, as provided in the following Revenue Memorandum Orders
(RMOs):
RMO No. 54-2000 RMO No. 57-2000
RMO No. 20-2002 RMO No. 31-2002
RMO No. 35-2007
 2. Prescribe reporting requirements on surveillance activities and the
implementation of the administrative sanction of suspension and
temporary closure of business;

3. Provide for immediate imposition of penalties for offenses committed, in

order to deter further commission thereof; and,

4. Maximize the degree of voluntary tax compliance, thereby increasing

revenue collections.

III. DEFINITION OF TERMS

1. A non-compliant taxpayer is defined as a taxpayer who, as a result of

surveillance / stocktaking activities, has been found to have committed
the violations enumerated in Item (1), Section IV of this Order, and who,
notwithstanding the issuance of several notices of violations, continues
to refuse to comply with the requirements provided under existing rules
and regulations.

2. For purposes of this Order, three (3) types of surveillance shall be utilized,
and are hereby defined as follows:

2.1. Covert Surveillance the surreptitious and undercover watch on

the business operations of a person for a certain period before the
conduct of the inventory of business documents evidencing receipt
of income as well as movement of goods or rendition of services;
or apprehension / seizure of the aforementioned business
documents and properties found to be the subject of violations of
the provision of the NIRC, as amended, and its implementing
regulations. (See Section 6(c), NIRC, as amended)

2.2. Overt Surveillance the type of surveillance which commences

with the inventory-taking of the business documents as mentioned
in 1.1 above, of the person under surveillance followed by the
actual observation and close monitoring of the business activities
of such person.

2.3. Short-Duration Surveillance (Tax Compliance Check) the type of

surveillance wherein the business operations of the target taxpayer
are observed for purposes of detecting non-compliance with the
Bureaus primary and secondary registration requirements. It is an
on-and-off activity which does not involve prolonged on-premises
observation.

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 3. The Investigating Offices participating in the implementation of this
Order shall include the following Bureau offices:
All Revenue District Offices
All Special Investigation Divisions
The National Investigation Division
The Policy Cases Division
The Large Taxpayers (LT) Audit and Investigation Divisions I and II
The LT Field Operations Division
The LT District Offices

IV. POLICIES

1. The National Internal Revenue Code, as amended, (hereinafter referred to

as NIRC) empowers the Commissioner of Internal Revenue to suspend
the business operations of a taxpayer on certain grounds, pertinent
provisions of which provides:

SEC. 115. Power of the Commissioner to Suspend the Business

Operations of a Taxpayer. - The Commissioner or his authorized representative
is hereby empowered to suspend the business operations and temporarily close
the business establishment of any person for any of the following violations:

(a) In the case of a VAT-registered Person.

(1) Failure to issue receipts or invoices;

(2) Failure to file a value-added tax return as required under
Section 114; or
(3) Understatement of taxable sales or receipts by thirty percent
(30%) or more of his correct taxable sales or receipts for the
taxable quarter.

(b) Failure of any Person to Register as Required under Sec. 236.

The temporary closure of the establishment shall be for the

duration of not less than five (5) days and shall be lifted only upon
compliance with whatever requirements prescribed by the
Commissioner in the closure order.

Thus, this Order shall provide the guidelines governing the enforcement of
the administrative sanction of suspension and temporary closure of
business relative to following provisions of the NIRC, as amended:

SEC. 113. Invoicing and Accounting Requirements for VAT-

Registered Persons.

(A) Invoicing Requirements. - A VAT-registered person shall issue:

(1) A VAT invoice for every sale, barter or exchange of goods or

properties; and

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 (2) A VAT official receipt for every lease of goods or properties,
and for every sale, barter or exchange of services.

(B) Information contained in the VAT Invoice or VAT Official

Receipt. The following information shall be indicated in the VAT
invoice or VAT official receipt:

(1) A statement that the seller is a VAT-registered person,

followed by his Taxpayers Identification Number (TIN);

(2) The total amount which the purchaser pays or is obligated to

pay to the seller with the indication that such amount includes
the value-added tax: Provided, that:

(a) The amount of tax shall be shown as a separate item in

the invoice or receipt;

(b) If the sale is exempt from value-added tax, the term

VAT-exempt sale shall be written or printed
prominently on the invoice or receipt;

(c) If the sale is subject to zero percent (0%) value-added tax,

the term zero-rated sale shall be written or printed
prominently on the invoice or receipt;

(d) If the sale involves goods, properties or services some of

which are subject to and some of which are VAT zero-
rated or VAT-exempt, the invoice or receipt shall clearly
indicate the breakdown of the sale price between its
taxable, exempt and zero-rated components, and the
calculation of the value-added tax on each portion of the
sale shall be shown on the invoice or receipt: Provided,
That the seller may issue separate invoices or receipts for
the taxable, exempt, and zero-rated components of the
sale.

(3) The date of transaction, quantity, unit cost and description of

the goods or properties or nature of the service; and

(4) In the case of sales in the amount of one thousand pesos

(P1,000) or more where the sale or transfer is made to a VAT-
registered person, the name, business style, if any, address
and Taxpayer Identification Number (TIN) of the purchaser,
customer or client.

(C) Accounting Requirements. Notwithstanding the provisions of

Section 233, all persons subject to the value-added tax under
Section 106 and 108 shall, in addition to the regular accounting
records required, maintain a subsidiary sales journal and
subsidiary purchase journal on which the daily sales and
purchases are recorded. The subsidiary journals shall contain
such information as may be required by the Secretary of Finance.

(D) Consequence of Issuing Erroneous VAT Invoice or VAT Official

Receipt.

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 (1) If a person who is not a VAT-registered person issues an
invoice or receipt showing his Taxpayer Identification Number
(TIN), followed by the word VAT:

(a) The issuer shall, in addition to any liability to other

percentage taxes, be liable to:
(i) The tax imposed in Section 106 or 108 without the
benefit of any input tax credit; and
(ii) A fifty percent (50%) surcharge under Section 248
(B) of this Code;

(b) The VAT shall, if the other requisite information required

under Subsection (B) hereof is shown on the invoice or
receipt, be recognized as an input tax credit to the
purchaser under Section 110 of this Code.

(2) If a VAT-registered person issues a VAT invoice or VAT

official receipt for a VAT-exempt transaction, but fails to
display prominently on the invoice or receipt the term VAT-
exempt sale, the issuer shall be liable to account for the tax
imposed in Section 106 or 108 as if Section 109 did not apply.

(E) Transitional Period. Notwithstanding Subsection (B) hereof,

taxpayers may continue to issue VAT invoices and VAT official
receipts for the period July 1, 2005 to December 31, 2005, in
accordance with Bureau of Internal Revenue administrative
practices that existed as of December 31, 2004.

SEC. 114. Return and Payment of Value-Added Tax.

(A) In General. - Every person liable to pay the value-added tax

imposed under this Title shall file a quarterly return of the amount
of his gross sales or receipts within twenty-five (25) days following
the close of each taxable quarter prescribed for each taxpayer:
Provided, however, That VAT-registered persons shall pay the
value-added tax on a monthly basis.

Any person, whose registration has been cancelled in accordance

with Section 236, shall file a return and pay the tax due thereon
within twenty-five (25) days from the date of cancellation of
registration: Provided, That only one consolidated return shall be
filed by the taxpayer for his principal place of business or head
office and all branches.

(B) Where to File the Return and Pay the Tax. - Except as the
Commissioner otherwise permits, the return shall be filed with and
the tax paid to an authorized agent bank, Revenue Collection
Officer or duly authorized city or municipal Treasurer in the
Philippines located within the revenue district where the taxpayer
is registered or required to register.

(C) Withholding of Value-added Tax. - The Government or any of its

political subdivisions, instrumentalities or agencies, including
government-owned or -controlled corporations (GOCCs) shall,
before making payment on account of each purchase of goods and
services which are subject to the value-added tax imposed in
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Sections 106 and 108 of this Code, deduct and withhold the value-
added tax due at the rate of five percent (5%) of the gross payment
thereof: Provided, That the payment for lease or use of properties or
property rights to nonresident owners shall be subject to ten percent
(10%) withholding tax at the time of payment. For purposes of this
Section, the payor or person in control of the payment shall be
considered as the withholding agent.

The value-added tax withheld under this Section shall be remitted

within ten (10) days following the end of the month the withholding
was made

SEC. 236. Registration Requirements.

(A) Requirements. - Every person subject to any internal revenue tax

shall register once with the appropriate Revenue District Officer:

(1) Within ten (10) days from date of employment, or

(2) On or before the commencement of business, or
(3) Before payment of any tax due, or
(4) Upon filing of a return, statement or declaration as required
in this Code.

The registration shall contain the taxpayer's name, style, place of

residence, business and such other information as may be required
by the Commissioner in the form prescribed therefor.

A person maintaining a head office, branch or facility shall

register with the Revenue District Officer having jurisdiction over
the head office, brand or facility. For purposes of this Section, the
term 'facility' may include but not be limited to sales outlets, places
of production, warehouses or storage places.

(B) Annual Registration Fee - An annual registration fee in the

amount of Five hundred pesos (P500) for every separate or distinct
establishment or place of business, including facility types where
sales transactions occur, shall be paid upon registration and every
year thereafter on or before the last day of January: Provided,
however, That cooperatives, individuals earning purely
compensation income, whether locally or abroad, and overseas
workers are not liable to the registration fee herein imposed.

The registration fee shall be paid to an authorized agent bank

located within the revenue district, or to the Revenue Collection
Officer, or duly authorized Treasurer of the city of municipality
where each place of business or branch is registered.

(C) Registration of Each Type of Internal Revenue Tax. - Every

person who is required to register with the Bureau of Internal
Revenue under Subsection (A) hereof, shall register each type of
internal revenue tax for which he is obligated, shall file a return
and shall pay such taxes, and shall update such registration of any
changes in accordance with Subsection (E) hereof.

(D) Transfer of Registration. - In case a registered person decides to

transfer his place of business or his head office or branches, it
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 shall be his duty to update his registration status by filing an
application for registration information update in the form
prescribed therefor.

(E) Other Updates. - Any person registered in accordance with this

Section shall, whenever applicable, update his registration
information with the Revenue District Office where he is
registered, specifying therein any change in type and other
taxpayer details.

(F) Cancellation of Registration.

(1) General Rule. The registration of any person who ceases to

be liable to a tax type shall be cancelled upon filing with the
Revenue District Office where he is registered, an application
for registration information update in a form prescribed
therefor.

(2) Cancellation of Value-added Tax Registration. A VAT-

registered person may cancel his registration for VAT if:

(a) He makes written application and can demonstrate to the

Commissioners satisfaction that his gross sales or
receipts for the following twelve (12) months, other than
those that are exempt under Section 109 (A) to (U), will
not exceed one million five hundred thousand pesos
(P1,500,000.00), or

(b) He has ceased to carry on his trade or business, and does

not expect to recommence any trade or business within
the next twelve (12) months.

The cancellation of registration will be effective from the first day

of the following month.

(G) Persons Required to Register for Value-added Tax.

(1) Any person who, in the course of trade or business, sells,

barters, or exchanges goods or properties, or engages in the
sale or exchange of services, shall be liable to register for
value-added tax if:

(a) His gross sales or receipts for the past twelve (12)
months, other than those that are exempt under Section
109 (A) to (U), have exceeded one million five hundred
thousand pesos (P1,500,000.00); or

(b) There are reasonable grounds to believe that his gross

sales or receipts for the next twelve (12) months, other
than those that are exempt under Section 109 (A) to (U),
will exceed one million five hundred thousand pesos
(P1,500,000.00).

(2) Every person who becomes liable to be registered under

paragraph (1) of this Subsection shall register with the
Revenue District Office which has jurisdiction over the head
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 office or branch of that person, and shall pay the annual
registration fee prescribed in Subsection (B) hereof. If he fails
to register, he shall be liable to pay the tax under Title IV as if
he were a VAT-registered person, but without the benefit of
input tax credits for the period in which he was not properly
registered.

(H) Optional Registration for Value-added Tax of Exempt Person.

(1) Any person who is not required to register for value-added tax
under Subsection (G) hereof may elect to register for value-
added tax by registering with the Revenue District Office that
has jurisdiction over the head office of that person, and paying
the annual registration fee in Subsection (B) hereof.

(2) Any person who elects to register under this Subsection shall
not be entitled to cancel his registration under Subsection
(F)(2) for the next three (3) years.

For purposes of Title IV of this Code, any person who has

registered value-added tax as the tax type in accordance with the
provisions of Subsection (C) hereof shall be referred to as VAT-
registered person who shall be assigned only one Taxpayer
Identification Number.

(I) Supplying of Taxpayer Identification Number (TIN). - Any

person required under the authority of this Code to make, render
or file a return, statement or other document shall be supplied with
or assigned a Taxpayer Identification Number (TIN) which he
shall indicate in such return, statement or document filed with the
Bureau of Internal Revenue for his proper identification for tax
purposes, and which he shall indicate in certain documents, such
as, but not limited to the following:

(a) Sugar quedans, refined sugar release order or similar

instruments;
(b) Domestic bills of lading;
(c) Documents to be registered with the Register of Deeds of
Assessor's Office;
(d) Registration certificate of transportation equipment by land,
sea or air;
(e) Documents to be registered with the Securities and Exchange
Commission;
(f) Building construction permits;
(g) Application for loan with banks, financial institutions, or other
financial intermediaries;
(h) Application for mayor's permit;
(i) Application for business license with the Department of Trade
& Industry; and
(j) Such other documents which may hereafter be required under
rules and regulations to be promulgated by the Secretary of
Finance, upon recommendation of the Commissioner.

In cases where a registered taxpayer dies, the administrator or

executor shall register the estate of the decedent in accordance
with Subsection (A) hereof and a new Taxpayer Identification

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 Number (TIN) shall be supplied in accordance with the provisions
of this Section.

In the case of a nonresident decedent, the executor or

administrator of the estate shall register the estate with the
Revenue District Office where he is registered: Provided, however,
That in case such executor or administrator is not registered,
registration of the estate shall be made with and the Taxpayer
Identification Number (TIN) supplied by the Revenue District
Office having jurisdiction over his legal residence.

Only one Taxpayer Identification Number (TIN) shall be assigned

to a taxpayer. Any person who shall secure more than one
Taxpayer Identification Number shall be criminally liable under
the provision of Section 275 on Violation of Other Provisions of
this Code or Regulations in General

SEC. 237. Issuance of Receipts or Sales or Commercial Invoices. - All

persons subject to an internal revenue tax shall, for each sale and transfer of
merchandise or for services rendered valued at Twenty-five pesos (P25.00) or more,
issue duly registered receipts or sales or commercial invoices, prepared at least in
duplicate, showing the date of transaction, quantity, unit cost and description of
merchandise or nature of service: Provided, however, That where the receipt is
issued to cover payment made as rentals, commissions, compensations or fees,
receipts or invoices shall be issued which shall show the name, business style, if any,
and address of the purchaser, customer or client.

The original of each receipt or invoice shall be issued to the purchaser,

customer or client at the time the transaction is effected, who, if engaged in business
or in the exercise of profession, shall keep and preserve the same in his place of
business for a period of three (3) years from the close of the taxable year in which
such invoice or receipt was issued, while the duplicate shall be kept and preserved
by the issuer, also in his place of business, for a like period.

The Commissioner may, in meritorious cases, exempt any person subject to

an internal revenue tax from compliance with the provisions of this Section.

SEC. 238. Printing of Receipts or Sales or Commercial Invoices. - All

persons who are engaged in business shall secure from the Bureau of Internal
Revenue an authority to print receipts or sales or commercial invoices before a
printer can print the same.

No authority to print receipts or sales or commercial invoices shall be

granted unless the receipts or invoices to be printed are serially numbered and shall
show, among other things, the name, business style, Taxpayer Identification Number
(TIN) and business address of the person or entity to use the same, and such other
information that may be required by rules and regulations to be promulgated by the
Secretary of Finance, upon recommendation of the Commissioner.

All persons who print receipt or sales or commercial invoices shall

maintain a logbook/register of taxpayers who availed of their printing services. The
logbook/register shall contain the following information:

(1) Names, Taxpayer Identification Numbers of the persons or entities for

whom the receipts or sales or commercial invoices were printed; and

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 (2) Number of booklets, number of sets per booklet, number of copies per
set and the serial numbers of the receipts or invoices in each booklet.

2. All surveillance activities shall be covered by Mission Orders (MOs)

[Annex A]. The MOs shall be printed as accountable forms to be
requisitioned by the Revenue Officials authorized to sign said MOs. MOs
issued should be chronologically recorded in the Mission Order Register.
The MOs shall be issued in triplicate / quadruplicate, to be distributed as
follows:

Original : Revenue Officer(s) directed to conduct the

surveillance, and to be attached to the
report on surveillance after termination
of the activity
2nd Copy : Investigating Offices / Divisions file copy
3rd Copy : Issuing Offices file copy
4th Copy : Taxpayers copy (in case of overt
surveillance)

3. The Accountable Forms Division shall be the custodian of blank MOs, and
shall maintain a register of all MOs issued to the following authorized
Revenue Officials:

Investigating Office / Division Authorized Revenue Official

3.1. Revenue District Office Regional Director

(RDO)
3.2. Special Investigation - do -
Division (SID)
3.3. National Investigation Asst. Commissioner (ACIR),
Division (NID) and Policy Enforcement Service (ES)
Cases Division (PCD)

3.4. Large Taxpayers (LT) Audit ACIR, Large Taxpayers Service

and Investigation Division I (LTS)
(Regular LTs) / LT Audit and
Investigation Division II
(Excise Taxpayers) / LT Field
Operations Division / LT
District Offices (LTDOs)

The Head of the Investigating Office / Division shall in turn request for
MOs from the concerned Regional Director / ACIR.

4. Overt Surveillance shall be conducted for a minimum period of ten (10)

days and a maximum period of thirty (30) days, unless otherwise extended
in writing by the authorized signatory. A weekly progress report shall be

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 rendered by the concerned implementing officers to the Head of the
Investigating Office / Division.

5. Round-the-clock observation / monitoring shall be done on the target

taxpayers business if the nature of the business so requires, as in the case
of motels and hotels.

6. The findings may be used as the basis for assessing taxes for the other
months or quarters of the same or different taxable years, and such
assessment shall be deemed prima-facie correct.

7. Implementing officers shall not be assigned new surveillance cases until

after they have reported the surveillance cases previously assigned to
them.

V. GUIDELINES AND PROCEDURES

A. Surveillance Activities

1. Prelude to Surveillance

Acquiring preliminary information on the person to be placed under

surveillance is necessary for an effective implementation thereof. Before
the actual surveillance, the Head of the Investigating Office / Division
must:

1.1. Acquaint himself with the business organization and economic

activity of the subject of surveillance (SUBJECT), the location of
the stores and outlets, the accounting records used and such other
relevant information as may be available and / or necessary. This
must be done with relative secrecy to prevent leakage of
information to the SUBJECT.

1.2. Prepare the necessary MO for approval and signature of the

concerned Regional Director / ACIR, as the case may be.

The number of MOs must correspond to the number of stores and

outlets to be observed / monitored in case of overt surveillance. A
different set of implementing officers shall be assigned for
different stores and outlets of the same SUBJECT.

1.3. Brief the implementing officer on the acts to be performed in

compliance with the MOs. The briefing shall be done within thirty
(30) minutes before the actual surveillance. To preserve the
confidentiality of the surveillance operation, the identity of the

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 target SUBJECT should be revealed to the implementing officers
only upon arrival at the site of operations.

2. Conduct of Surveillance

2.1. Revenue Officer Authorized to Conduct Surveillance Activities on

Business establishments for Possible Violations of Sections 113,
114, 236, 237 and 238 of the NIRC, as amended. At least two
(2) implementing officers comprised of Revenue Officers (ROs)
(Assessment/Excise), Intelligence Officers (IOs) and special
Investigators (SIs) assigned in the following investigating
offices/divisions shall be authorized to conduct surveillance
activities on identified business establishment based on a validly
issued mission order signed by the concerned authorized revenue
official:

Authorized Revenue
Investigating Office/Division
Official
(a) Revenue District Office
Regional Director
(b) Special Investigation Division
(c) National Investigation Division
ACIR ES
(d) Policy Cases Division
(e) LT Audit & Investigation Division I
(Regular Large Taxpayer)
(f) LT Audit & Investigation Division I
ACIR LTS
(Excise Taxpayer)
(g) LT Field Operations Division
(h) LT District Office

2.2. Mandatory Requirement for the Conduct of Surveillance and

Apprehension of Business Establishments for Non-Compliance
with the Provisions of Section 113, 114, 236, 237 and 238 of the
NIRC, as amended. No surveillance activities shall be conducted
nor apprehension effected unless the same has been authorized by
a mission order issued in accordance with the provisions of this
Order.

2.3. Implementing officers conducting the surveillance must possess

the following qualities:
Ordinary appearance The implementing officer must not have
any outstanding physical characteristic or wear any distinctive
article (e.g. any article which can readily identify him to be an
employee of the Bureau, such as wearing of uniform) which
may easily attract the SUBJECTs or his representatives
attention. This is essential for covert surveillance.
Ability to act naturally under all circumstances;

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 Alertness;
Resourcefulness;
Keen observation and good memory; and,
Patience and endurance.

2.4. Performance of Surveillance Activities

Generally, surveillance may be either covert or overt. Covert

surveillance will eventually become overt surveillance once the
implementing officer informs the SUBJECT of his presence and
purpose.

2.4.1. Covert Surveillance

a. Observe the business operations of the SUBJECT.

Develop leads from other sources by obtaining
information from neighboring business establishments,
locating additional outlets or warehouses of the
SUBJECT.

b. Take note of the suppliers and buyers, and volume of

deliveries made to any by the SUBJECT. This activity
should be done discreetly. The records of the supplier
and buyer may thereafter be accessed and compared
with the data declared by the SUBJECT.

c. Observe and watch out for any unregistered cash

register machines (CRMs) being used, especially during
peak hours.

d. Determine violations of internal revenue laws, rules and

regulations committed by the SUBJECT, and the
frequency of such violations.

e. Apprehend the taxpayer by issuing on the spot an

Apprehension Slip (AS) [Annex B], in duplicate,
once caught in the act of not issuing official receipts /
invoices, or issuing unregistered official receipts /
invoices or otherwise, found to be in violation of the
provisions of Sections 113, 236, 237 and 238 of the
NIRC of 1997.

f. Report immediately to the Head of the Investigating

Office / Division the result of the apprehension not later
than the following day from the issuance of the AS.

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2.4.2. Overt Surveillance

The most important factor in overt surveillance is the

element of surprise. The SUBJECT must be caught
unaware to prevent him from committing acts which may
defeat the purpose of the surveillance. Those caught in the
act of committing crimes punishable under the Tax Code
must be immediately apprehended.

After the covert surveillance has been undertaken, the

following procedures shall be performed by the
implementing officers who should always be ready to
present their BIR Identification Cards:

a. Inform the SUBJECT of the purpose and duties of the

implementing officer as stated in the MO.

b. Conduct an inventory of all unused sales invoices,

official receipts and such other documents used in the
movement of goods.

c. List all the above documents in the Surveillance Form

(SF) [Annex C].

d. Seize unauthorized official receipts or invoices and

accomplish the AS in duplicate. Issue the original copy
to the SUBJECT. Report immediately to the Head of
the Investigating Office / Division the results of the
apprehension not later than the following day from the
issuance of the AS.

e. After all the unused official receipts / invoices are listed

in the Surveillance Form, sign the first and last receipts
/ invoices in each booklet stating therein the date and
time when the inventory was made.

f. For official receipts or invoices from partly used

booklets, sign the duplicate / file copy of the last
invoice used. In case there is no chronological issuance
of invoices / official receipts, list down the unused
invoices / official receipts, sign the first and last pages
of the un-issued invoices / official receipts in each
booklet and indicate the date and time when the
inventory was made.

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 g. Return all the official receipts to the SUBJECT or his
authorized representative and inform him that official
receipts / invoices must be issued chronologically.
Request the SUBJECT or his authorized representative
to sign the Surveillance Form. If acknowledgement of
the Surveillance Form is refused, have the certificate
signed by at least two (2) witnesses present and leave a
copy of the Surveillance Form with the SUBJECT or
his authorized representative.

h. Observe / monitor the daily sales in the stores or the

daily production and daily removal from or deliveries to
the factories, from the time they open to the time they
close.

i. Summarize all the sales / official receipts at the end of

each day for the entire duration of the surveillance and
enter the figures on the space provided in the
Surveillance Form.

The procedures outlined in this Order are general guides in

the conduct of the surveillance. The implementing officer
is not precluded from applying additional procedures which
he may deem necessary based on his findings or initial
evaluation of the case, provided that the same are carried
out with due regard for the SUBJECTs legal rights.

2.4.3. Conduct of Surveillance for Taxpayers Using Cash

Register Machines (CRMs) and Point-of-Sale Machines
(POSs)

a. Take an inventory of all CRMs and POSs, whether used

for issuance of invoices or for internal control purposes.
The number of CRMs / POSs found in the premises
may later on be reconciled with the data available in the
Bureau as to the number of CRMs / POSs authorized to
be used.

b. Verify whether the store / establishment using the CRM

/ POS has maintained a Cash Register Sales Book or
electronic journal identified to each CRM / POS used.

c. Check the permits issued and the stickers attached to

each CRM / POS whether they tally with the brand and
serial numbers of the CRMs / POSs authorized to issue
receipts. If the serial number in the sticker does not
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 tally with that of the machine, request the subject to
present the original copy of the permit to use CRM /
POS. Likewise, request the SUBJECT or his
representative to show the reserve units. If the
SUBJECT or his representative refuses, look for the
reserve units. If they are not found in the business
premises, prepare a memorandum recommending the
issuance of a subpoena for the taxpayer to produce the
reserve units.

d. Seize all unauthorized CRMs / POSs and accomplish

the AS in duplicate. Issue the original copy of the AS
to the taxpayer. Report immediately to the Head of the
Investigating Office / Division the result of the
apprehension / seizure not later than the following day
from the issuance of the AS.

e. Read through the memory of the machine by using the

Z keys. Secure at least two (2) tapes for two (2)
readings.

e.1. Identify whether the CRM / POS is resettable or

non-resettable by means of the reading and match
it with the application for permit.

e.2. Inquire from the CRM / POS operator how many

times they read the machine in a day.

e.3. Enter the readings and other pertinent information

in the Cash Register Machine / Point-of-Sale
Machine Surveillance Form (CRM/POS-SF)
[Annex C-1]. Said Form shall be accomplished
for each CRM / POS.

f. Sign the tape and indicate the date and time thereon
before the CRM / POS is put to use for the day, if
possible.

g. Secure the machine tape showing the Z reading every

end of the day until the last day of the surveillance.

3. Analysis of Surveillance Results

3.1. Extrapolate the data gathered from the surveillance by using the
following formulas:

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 To get the Average Daily Sales:

Total Sales During Surveillance

Average Daily
Total No. of Days Under =
Sales (ADS)
Surveillance

To get the Average Quarterly Sales:

ADS x 30 days x 3 months = Average Quarterly Sales (AQS)

3.2. Compare the extrapolated data with the recently filed monthly /
quarterly internal revenue tax returns to determine significant
variations in sales / revenues.

3.3. Determine violations of internal revenue laws, rules and

regulations of the SUBJECT such as the usage of unregistered
CRM / POS or invoices / official receipts and non-issuance of
invoices / official receipts.

4. Action on Surveillance Results

If after the conclusion of the surveillance, there is a sufficient ground for

the closure of the establishment as provided for under Section 115 of the
NIRC, as amended, a recommendation shall be made to effect such
closure.

If the result of the surveillance made likewise indicates that the taxpayer
had not been, in fact, correctly reporting income for tax purposes, and that
the veracity of his accounting records is not reliable, the Commissioner or
Regional Director concerned shall issue a Letter of Authority (LA) for the
investigation of the taxpayer. The Revenue Officer named in the LA shall
proceed with the audit and cause the assessment of the taxpayers internal
revenue tax liabilities, based either on: (1) surveillance, pursuant to
Section 6[C]; (2) best evidence rule, as provided under Section 6[B],
NIRC as amended; and / or (3) the result of the tax audit.

5. In order to avoid multiple surveillance activities being conducted upon one

taxpayer by several Offices of the Bureau and to clearly define which
Office shall conduct surveillance activities, the following rules shall be
observed:

5.1. If the basis of the surveillance activities comes from information

gathered from the internal sources of the Bureau, e.g., information
in the tax returns, information required to be furnished by certain
government agencies as well as taxpayers to the Bureau on a
regular basis (e.g., BOC, LRA, BIR RELIEF System, etc.)
Page 17 of 29
 pursuant to Memoranda of Agreement executed with the Bureau
and revenue regulations issued, the surveillance activities shall be
conducted by the Revenue District Office (RDO), Large Taxpayers
Audit and Investigation Division I (LTAID I), Large Taxpayers
Audit and Investigation Division II (LTAID II), or Large
Taxpayers District Office (LTDO) with respect to taxpayers falling
under their respective jurisdictions; and

5.2. If the basis of surveillance activities comes from confidential

information filed by an informer or from other external sources,
the surveillance activities shall be conducted by the National
Investigation Division (NID) and Policy Cases Division (PCD).
The ACIR Enforcement Service, however, in consultation with
the Head of the Investigating Office, may decide to refer the case
to the Special Investigation Division (SID) or RDO/LTDO, if the
case so warrants.

B. Suspension or Temporary Closure of Business.

1. Grounds. The following shall be the only grounds for suspension or

temporary closure of business:

(a) Failure to issue receipts or invoices by a VAT-registered or registrable

taxpayer;
(b) Failure to file a Value-Added Tax return;
(c) Understatement of taxable sales or receipts by 30% or more of the
correct amount thereof in the case of a VAT-registered or registrable
taxpayer; or,
(d) Failure to register.

2. Procedures for Recommending the Suspension or Temporary Closure

of Business

2.1. Documentary Requirements

The recommendation of the concerned head of the investigating

office/division to the Regional Director or ACIR Enforcement
Service (ES) or ACIR, Large Taxpayers Service (LTS), as the case
may be, to suspend or temporarily close business shall invariably
be accompanied by documentary proof in support of the particular
violation, as follows:

2.2. Failure to Issue Value-Added Tax Invoice/Receipts

2.2.1. A certification by the record custodian concerned to the
effect that the Taxpayer Identification Number of the
taxpayer has been verified as correct;

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 2.2.2. The Mission Order issued to the apprehending officer, if
any;
2.2.3. Apprehension slip detailing the items seized;
2.2.4. The Items seized such as the pad of invoices where
duplicate and triplicates are left blank or not filled up;
2.2.5. Sworn statement under oath of the apprehending revenue
officer stating the circumstances leading to the
apprehension; or,
2.2.6. Other evidence, if available.

2.3. Failure to File Value-Added Tax Returns

2.3.1. A certification by the record custodian that the Taxpayer
Identification Number of the taxpayer has been verified as
correct;
2.3.2. A Certification from the revenue District Officer concerned
and/or the accredited banks, collection agent or duly
authorized Treasurer of the City or Municipality where the
principal office of the offender is located that no return was
filed;
2.3.3. The memorandum report of the Revenue Enforcement
Officer narrating the fact of non-filing, the grounds relied
upon for such a conclusion, with attachments, if any; or,
2.3.4. The memorandum report shall be supported by at least a
preliminary finding as to the amount of sales and the tax
evaded during the quarters under investigation, these to be
reflected in the prescribed reportorial forms and working
papers.

2.4. Understatement of Taxable Sales by 30% or More

2.4.1. The return filed;
2.4.2. The taxpayers records or part thereof as will show or from
which it can be shown by other competent evidence that an
understatement of sales/receipt has been committed.
Invariably, the investigating enforcement officer should
take custody over these records under proper receipt as
evidence;
2.4.3. The documents or certified copies thereof obtained through
access to records of third persons or entities as provided
under Sec. 5 of the NIRC, as amended, which tend to show
the actual sales/receipts of the taxpayer;
2.4.4. The memorandum report of the investigating revenue
enforcement officer; or,
2.4.5. The prescribed reportorial forms, including working papers
reflecting the details of the investigators finding of
understatement.

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 2.5. Failure of a Value-Added Tax Subject Person to Register
2.5.1. Any one or a combination of the documents which show
the line of business of the taxpayer, such as Certificate of
Registration with the DTI, SEC, Treasurers Office of the
concerned LGU, BOI, BIR;
2.5.2. Any one or a combination of documents showing that the
annual gross sales/receipts from Value-Added Tax covered
transactions of the taxpayer during the previous year
exceed one million five hundred thousand pesos
(P1,500,000.00) or have exceeded said amount during the
current year, such as the financial statements, income and
business tax returns, reports of investigation by revenue
enforcement officers, and the taxpayers own records. In
the case of an importer, the letters of credit opened, import
documents, or certifications from the Bureau of Customs/
Bureau of Import Service, among others;
2.5.3. Certification from the Revenue District Officer who has
jurisdiction over the taxpayer to the effect that the latter did
not register as a Value-Added Tax person;
2.5.4. Late registration of business who shall have registered shall
carry a penalty of Five Thousand Pesos (P5,000.00).

3. Confrontational Requirements

3.1. Consistent with the requirements of due process, the report of the
handling Revenue Officer shall be concurred in by the Head of the
investigating office. The findings of the investigating office shall
be reviewed by a Review Board composed of the following:

3.1.1. For Regional Cases. The Regional Review Board shall

be composed of the following revenue officials:

Chairman : Regional Director

Members : Chief, Assessment Division
Chief, Legal Division
RDO having jurisdiction over the taxpayer

3.1.2. For National Office Cases. The National Office Review

Board shall be composed of the following revenue
officials:

Chairman : Asst. Commissioners (ACIRs), ES /LTS

Members : Representative, Office of the Commissioner
Representative, Office of the Deputy
Commissioner (Legal and Inspection
Group)

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 Representative, Office of the Deputy
Commissioner (Operations Group)
Representative, Legal Service

3.1.3. The Commissioner of Internal Revenue shall serve as the

Overall Chairman of the Regional Office Review Boards
and the National Office Review Board.

The Review Boards must act on reports within five (5) days from
receipt thereof. The Review Boards shall convene, upon the
initiative of the chairperson, whenever necessary.

If a report is approved by a Review Board, the concerned Regional

Director or the ACIR, Enforcement Service/LTS, as the case may
be, shall, in his capacity as Chair of the Review Board, sign and
issue to the taxpayer concerned a Forty-Eight (48) Hour Notice,
requiring him to explain under oath within forty eight (48) hours
why he should not be dealt with administratively, by suspension
of business or temporary closure of his establishment, and/or
criminally, for violation of pertinent provisions of the Tax Code.

In cases concerning duly validated discrepancies in sales /

purchases covered by Letter Notices under the Tax
Reconciliation System or the Third Party Information Program,
a Letter Notice and follow-up letters sent and duly received by the
taxpayer shall be considered as sufficient compliance with the
48-Hour Notice.

3.2. Upon the taxpayers submission of the explanation, or if none is

submitted on or before the deadline, the Review Board headed by
the Regional Director or the ACIR, Enforcement Service/LTS,
shall decide whether or not to terminate the case, or to pursue
administrative / criminal action against the taxpayer, as the case
may be.

3.3. If a Review Board deems it necessary to pursue administrative or

criminal action against a non-compliant taxpayer, it shall cause
the preparation of a 5-Day VAT Compliance Notice (VCN)
[Annex D], which shall be issued in lieu of the 10-Day VCN, to
expedite the resolution of the case at hand. The 5-Day VCN
shall be signed by the Chair of the Review Board concerned.

3.3.1. The 5-Day VCN, with details of the findings of the

investigating office as approved by the Review Board,
shall be served immediately to the taxpayer by the

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 Regional Director / ACIR-LTS / ACIR-Enforcement
Service, as the case may be.

3.3.2. The 5-Day VCN shall likewise state the particular

provision(s) of the NIRC that was / were violated by the
taxpayer, and for which rectification must be done,
including payment of the required deficiency taxes and
penalties due therefor.

3.3.3. The taxpayer may again refute the findings of the BIR
within two (2) days from receipt of the VCN, and submit
his response to the Review Board.

3.3.4. The Review Board shall, in turn, immediately transmit the

taxpayers response to the Investigating Office concerned,
for evaluation.

3.3.5. The Investigating Office concerned shall, within three (3)

days from receipt thereof, evaluate, a taxpayers response
to a 5-Day VCN, and prepare the corresponding response
thereto. The response letter shall then be signed by the
Chair of the Review Board.

3.3.6. Upon receipt by the BIR of the protest, the running of the
five (5) day compliance period is deemed suspended,
and shall resume only upon receipt by the taxpayer of the
BIRs resolution on the protest.

C. Execution and Enforcement

1. In the event that a taxpayer --

Refuses, neglects or fails to submit within the prescribed period, a

response to a VCN;
Submitted a response that was later found to be insufficient; or,
Refuses, neglects or fails to comply with the terms of the 5-Day VCN,

the Review Board concerned shall prepare a memorandum report

recommending the closure of the establishment, for the approval of the
Commissioner. Said report shall include the proposed Closure Order
(Annex E), supported by the necessary documentation, for the
approval and signature of the Commissioner.

The Closure Order shall be prepared in quintuplicate (five [5] copies), to

be distributed as follows:

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 Original : Taxpayers copy
2nd Copy : Office of the Commissioner
3rd Copy : Office of the Regional Director / ACIR concerned
4th Copy : Investigating Office
5th Copy : Investigating Officer (receiving copy)

Each Investigating Office must nominate at least three (3) non-

compliant taxpayers per month, for issuance of Closure Orders.

2. The signed Closure Order shall be returned by the Office of the

Commissioner, together with all supporting documents, to the Review
Board concerned, for immediate service to the non-compliant taxpayer.

3. The service of the Closure Order shall be accompanied by a copy of the

memorandum report of the Review Board concerned, duly approved by
the Commissioner, indicating therein the basis for the Closure.

4. However, if in the interim the non-compliant taxpayer rectifies the

violation pursuant to Section VIII (Compliance by Taxpayer) hereof, the
Chair of the Review Board concerned shall desist from implementing
the Closure Order, and shall immediately communicate such
information to the Commissioner.

5. The execution of the Closure Order shall consist in the physical closing of
the doors or other means of ingress of the establishment, and the sealing
thereof, with the appropriate security devices (padlocks, etc.) and the
BIRs official seal.

6. Where deemed necessary, the execution of the Closure Order shall be

carried out with the assistance of elements of the Philippine National
Police (PNP) or Barangay Officials in the locality, in accordance with the
Memorandum of Agreement between the Bureau of Internal Revenue and
the PNP or concerned Barangay Officials.

7. To create an immediate impact on the publics consciousness, and to

increase taxpayer awareness of the BIRs intensified campaign to
pursue non-compliant taxpayers, the implementation of the Closure
Order and Temporary Suspension for a particular taxpayer to be carried
out by a team of revenue officials led by the Regional Director / the
ACIR ES/LTS, and the Head of the Investigating Office concerned, or
in appropriate instances, by the Commissioner of Internal Revenue,
must be widely publicized through press releases, press conferences,
and, when possible, the televised coverage of the actual closure /
suspension of business operations of a non-compliant taxpayer.

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 7.1. The Taxpayer Assistance Service shall coordinate with the
National Office Review Board and the Office of the
Commissioner in all activities intended to publicize the
operations and accomplishment of Oplan Kandado, utilizing
all available communications media in increasing the publics
awareness of the objectives of the program.

8. All reports and documents signed by the Commissioner in relation to the

implementation of this Order shall not require the concurrence of other
BIR officials as mandated in previous issuances.

9. The closure and temporary suspension of business under a duly-

approved Closure Order shall not preclude the Bureau from filing the
appropriate charges, if evidence so warrants, against the taxpayer
concerned; or in the case of corporate taxpayers, against the responsible
officers of the corporation, under the Run After Tax Evaders (RATE)
Program of the Bureau.

VI. DURATION OF CLOSURE

1. The closure of a business establishment shall last for a period of not less
than five (5) days, and shall be in force until the violation is rectified.

Upon rectification by the taxpayer of the violation pursuant to Section

VIII hereof, the Review Board concerned shall prepare a memorandum
report recommending the lifting of the closure order, for the approval of
the Commissioner. Said report shall include the proposed Lifting of
Closure Order (Annex F), supported by the necessary documentation,
for the approval and signature of the Commissioner.

2. The Lifting of Closure Order shall be prepared in quintuplicate (five [5]

copies), to be distributed as follows:

Original : Taxpayers copy

2nd Copy : Office of the Commissioner
3rd Copy : Office of the Regional Director / ACIR concerned
4th Copy : Investigating Office
5th Copy : Investigating Officer (receiving copy)

3. In the event that the Commissioner approves a recommendation for the

lifting of a Closure Order, the signed Lifting of Closure Order shall be
returned by the Office of the Commissioner, together with all supporting
documents, to the Review Board concerned, for immediate service to the
non-compliant taxpayer.

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 4. The service of the Lifting of Closure Order shall be accompanied by a
copy of the memorandum report of the Review Board concerned, duly
approved by the Commissioner, indicating therein the basis for the
lifting of the sanction.

VII. COMPLIANCE BY TAXPAYER

1. The Closure Order shall only be lifted if the violation/s as stated in the 5-
Day VAT Compliance Notice is rectified by the taxpayer by:

1.1. Complying with the registration requirements set forth in Sections

236 and 238 of the NIRC, in case of failure to register;

1.2. Complying with the invoicing requirements as set forth in Sections

113 and 237, in case of failure to issue receipts / invoices;

1.3. Filing of VAT returns which have not been filed and paying the
amount of taxes due thereon;

1.4. Amending previously filed VAT returns to reflect the correct

taxable sales/receipts which were previously understated due to the
failure to issue sales invoices/receipts or due to underdeclaration of
sales/receipts.

2. Nonetheless, the taxpayer is not precluded from amending/filing returns

covering other tax liabilities as a result of the BIR findings as aforestated.

3. The original returns/amended returns and payment of the taxes due,

inclusive of penalties, shall be filed with the AABs of the BIR Office (i.e.,
RDO or LTDO or LTAID I or LTAID II, whichever is applicable) where
the taxpayer is registered or required to be registered. The registration of
the business as well as other registration-related activities shall be made
with the appropriate BIR Office where the taxpayer is required to be
registered.

4. On the basis of the compliance made, the concerned BIR Office shall issue
a Certification to the effect that the particular violation has been rectified
by the taxpayer. Such Certification shall reflect the amount of taxes paid
together with the Official Receipt Number issued by the AAB/Collection
Agent and the particular returns filed or amended by the taxpayer, in case
of any; or the Certificate of Registration Number/Taxpayer Identification
Number (TIN) issued to the taxpayer, in case of failure to register.

5. A copy of such Certification, together with the copies of the Certificate of

Registration, AAB/Collection Agent Official Receipt and/or VAT returns
Page 25 of 29
 filed, or other documents to prove compliance, shall be submitted to the
Review Board as evidence of the subsequent compliance made which shall
be the basis for the recommendation of the lifting of the closure order as
provided in Section VII hereof.

6. If the amounts declared in the VAT returns filed do not tally with the
computed tentative amount of underdeclaration of gross
sales/receipts/other taxable base as indicated in the report of the Review
Board, the taxpayer must be able to dispute the accuracy of the computed
figures reported by the revenue officers and must be able to cite the
reasons why the tentative figures as computed by the BIR were not the
figures followed in the filed returns. The report of the investigating office
as reviewed by the Review Board shall recommend the appropriate action
thereon for the approval of the DCIR-Legal and Inspection Group.

VIII. EFFECT OF THE LIFTING OF THE CLOSURE ORDER

1. The lifting of the closure order shall be done in cases when there has been:

1.1. Subsequent filing or amendment of returns with the payment of the

tax inclusive of statutory penalties;

1.2. Subsequent registration with the payment of the corresponding

compromise penalties;

1.3. Payment of deficiency taxes inclusive of penalties corresponding

to the sales where no invoices/receipts have been issued; and,

1.4. Payment of deficiency taxes inclusive of penalties corresponding

to the understatement of taxable sales or receipts.

2. If there is no 100% compliance with the tentative amounts provided in the

5-Day VCN / Letter Notice, but the taxpayer partially complies by
amending his returns, wherein the amounts reflected in the amended
returns are based on the ratio and percentages reflected in the original
returns filed, such compliance shall still be considered as basis for the
recommendation for the lifting of the closure order, Provided that the tax
payments in the amended returns filed or on returns initially filed, in case
of no previously filed returns, for business tax shall not be less than the
following:

In case of seller of services, ten percent (10%) of undeclared gross

receipts as found by the BIR; or one hundred ten percent (110%) of
the adjusted basic tax due (after considering underdeclaration),
whichever is higher.

Page 26 of 29
 In case of seller of goods, five percent (5%) of undeclared gross sales
as found by the BIR; or one hundred ten percent (110%) of the
adjusted basic tax due (after considering underdeclaration),
whichever is higher.

Provided, further, that notwithstanding compliance with the 5-Day VAT

Notice and the subsequent lifting of the closure order, the taxpayer may
still be subjected to audit of returns filed (original or amended returns)
and records pertaining to all his tax liabilities.

3. The lifting order shall not release the taxpayer from the compliance
requirements and from the penalties prescribed by the Tax Code for the
violation which shall be dealt with by criminal prosecution or by
compromise settlement, at the discretion of the Commissioner of Internal
Revenue. In case of compromise settlement, however, the same shall be
approved by MANCOM, pursuant to Revenue Regulations No. 13-2001.
Majority vote of the members of the MANCOM shall, with the
concurrence of the Commissioner, constitute a decision of MANCOM.

IX. REPORTORIAL REQUIREMENTS

1. On Surveillance Activities

1.1. The Heads of the Investigating Offices / Divisions shall prepare a

Status Report on the Surveillance Activities [Annex G] within
ten (10) days after the close of each month and shall submit the
same to the following:

Investigating Office Recipient of Reports

RDOs
Regional Office
SIDs
NID
Enforcement Service
PCD
Large Taxpayers (LT)
Audit and
Investigation Division
I (Regular LTs)
LT Audit and
Investigation Division Large Taxpayers Service
II (Excise Taxpayers)
LT Field Operations
Division
LT District Offices
(LTDOs)

Page 27 of 29
 1.2. The Regional Offices, the Enforcement Service and the Large
Taxpayers Service shall then submit consolidated Status Reports,
following the same format prescribed for the Report, and submit
the same to the Office of the Commissioner, within fifteen (15)
days from the close of each month.

1.3. In addition to the above report, the Regional Directors, and the
ACIRs of the Enforcement Service and the Large Taxpayers
Service shall prepare a List of Mission Orders Issued [Annex H]
and submit the same to the Office of the Commissioner on or
before the fifth day following the end of the month of issuance.

2. On Monthly Accomplishment Reports

All Review Boards shall submit, on or before the tenth (10) day of the
following month, these reports:

Monthly Report on 5-Day VCNs Issued (Annex I);

Monthly Report on Closure Orders Issued and Served (Annex J);

Monthly Report on Lifting of Closure Orders Issued and Served

(Annex K); and,

Monthly Report on the Oplan Kandado Program (Annex L).

2.1. The Regional Review Boards shall submit their monthly

accomplishment reports to the Deputy Commissioner (Operations
Group), and to the Office of the Commissioner.

2.2. The National Office Review Board, however, shall submit its
monthly accomplishment report directly to the Office of the
Commissioner.

X. REPEALING CLAUSE

All revenue issuances inconsistent herewith are hereby repealed or modified

accordingly. Unless inconsistent with the policies and guidelines herein prescribed, all
other rules and policies pertaining to the enforcement of the administrative sanction of
suspension and temporary closure of business shall be strictly observed and followed.

Page 28 of 29
XI. TRANSITORY PROVISIONS

For closure cases initiated prior to the issuance of this Order but whose
disposition have remained pending as of its effectivity, the pertinent provisions herein
shall apply to the remaining stages. Thus, in a closure case where the action left to be
done prior to the effectivity of this Order is the lifting thereof, the provisions relative to
the lifting of the closure order and other procedures to be performed thereafter as herein
provided shall be observed.

XII. EFFECTIVITY

This Order shall take effect immediately.

(Original Signed)
SIXTO S. ESQUIVIAS IV
Commissioner of Internal Revenue

A-

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