Likewise, service of the FAN/FLD to the taxpayer should be made only by registered mail or by personal delivery. If sent by personal delivery, the taxpayer or his duly authorized representative shall acknowledge receipt thereof in the duplicate copy of the letter of demand, showing the following: (a) His name; (b) signature; (c) designation and authority to act for and in behalf of the taxpayer, if acknowledged received by a person other than the taxpayer himself; and (d) date of receipt thereof.
It is therefore imperative on the part of the tax authorities to comply with these requirements in order to validly assert the right of the Government to assess and collect the correct taxes from the taxpayers. The necessity of these requirements is recognized by the Supreme Court in one case, in which it held that “the issuance of a valid formal assessment is a substantive prerequisite to tax collection, for it contains not only a computation of tax liabilities but also a demand for payment within a prescribed period, thereby signaling the time when penalties and interests begin to accrue against the taxpayer and enabling the latter to determine his remedies therefor. Due process requires that it must be served on and received by the taxpayer.”
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