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ABC Corporation, a company based in Iloilo City, receives a Letter of Authority (LOA) dated June 30, 2026 from the Commissioner of Internal Revenue authorizing Revenue Officer to examine ABC's books and other pertinent records for calendar years 2024 and 2025, to be conducted at ABC's premises. The LOA (i) authorizes entry and inspection of the books, ledgers, invoices, payroll records, and other pertinent records; (ii) directs ABC and its officers to produce the books and records; and (iii) instructs CityBank, the custodian of ABC's bank statements and related records, to cooperate and to produce the bank statements for the same period. The LOA lists CityBank as custodian and does not mention other banks. It does not specify the exact number of years beyond 2025 and is served on ABC's Chief Financial Officer on July 2, 2026. On July 7, 2026, CityBank 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.