Despite acquittal in a criminal case based on reasonable doubt, a taxpayer can be held civilly liable for a tax assessment when the
prosecution proves its case in the civil action by a preponderance of evidence. Without a valid LOA, the assessment by the BIR is void.
Circularizing the amended answer to Question No. 2 of Revenue Memorandum Circular (RMC) No. 85-2018 in relation to the issuance of
Electronic Certificate Authorizing Registration (eCAR) in the transfer of real properties