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Veridian Textiles, Inc., a corporation with principal office in Quezon City, receives a Letter of Authority (LOA) dated September 12, 2025 from the Commissioner of Internal Revenue authorizing Revenue Officer Mateo Reyes to examine Veridian’s books of accounts and other pertinent records for calendar years 2021 and 2022, to be conducted at Veridian’s premises. The LOA (i) authorizes entry and inspection of the books, ledgers, invoices, payroll records, and other pertinent records; (ii) directs Veridian and its officers to produce the books and records; and (iii) instructs Commonwealth Bank, the custodian of Veridian’s bank statements and related records, to cooperate and to produce the bank statements for the same period. The LOA lists Commonwealth Bank as custodian and does not mention other banks. It does not specify the exact number of years beyond 2022 and is served on Veridian’s Chief Financial Officer on September 14, 2025. On September 18, 2025, Commonwealth Bank refused to release the bank statements, citing Bank Secrecy Law (RA 1405) and asserting that the LOA does not explicitly authorize the bank to disclose the records without a court order. The Revenue Officer contends that the LOA’s language “bank statements and related records” is sufficient to include the bank records, and that the LOA is a valid instrument directing bank cooperation. (a) Identify the controlling doctrine or principle that governs the validity and scope of a Letter of Authority in tax examinations. (b) Determine, on these facts, whether the LOA covers the requested bank statements and whether Commonwealth Bank must release them without a court order. (c) If the LOA is defective for lack of precise scope, explain the remedy for Veridian and the likely impact on the audit and any resulting assessments.

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Clara

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