Due process in the constructive service of BIR notices

In an En Banc decision last March 2015, the Court of Tax Appeals (CTA) ruled that even if a taxpayer or his duly authorized representative refuses to acknowledge receipt of assessment notices for deficiency taxes issued by the Bureau of Internal Revenue (BIR), personal delivery shall be considered “constructive service” provided that such notices are left at the premises of the taxpayer and such fact is attested to by at least two revenue officers other than the revenue officer who constructively served them.