Revised Rules of the Court of Tax Appeals

Section 1

A party desiring to present voluminous documents in evidence before the Court may secure the services of an independent certified Public Accountant (CPA) at its own expense. The Court shall commission the latter as an officer of the Court solely for the purpose of performing such audit functions as the Court may direct. (n)

Sec 2

The independent CPA shall perform audit functions in accordance with the generally accepted accounting principles, rules and regulations, which shall include: (a) Examination and verification of receipts, invoices, vouchers and other long accounts; (b) Reproduction of, and comparison of such reproduction with, and certification that the same are faithful copies of original documents, and pre-marking of documentary exhibits consisting of voluminous documents; (c) Preparation of schedules or summaries containing a chronological listing of the numbers, dates and amounts covered by receipts or invoices or other relevant documents and the amount(s) of taxes paid; (d) Making findings as to compliance with substantiation requirements under pertinent tax laws, regulations and jurisprudence; (e) Submission of a formal report with certification of authenticity and veracity of findings and conclusions in the performance of the audit; (f) Testifying on such formal report; and (g) Performing such other functions as the Court may direct.

Sec 3

The submission by the independent CPA of pre-marked documentary exhibits shall be subject to verification and comparison with the original documents, the availability of which shall be the primary responsibility of the party possessing such documents and, secondarily, by the independent CPA. The findings and conclusions of the independent CPA may be challenged by the parties and shall not be conclusive upon the Court, which may, in whole or in part, adopt such findings and conclusions subject to verification. (n)

Sec 4

Whenever practicable and convenient, the Court may apply the procedure prescribed in Rule 32 of the Rules of Court. When the parties stipulate that a commissioner’s findings of fact shall be final, only questions of law shall thereafter be considered. (n)

Sec 5

The Court shall allow the commissioners such reasonable compensation as the circumstances of the case may warrant. (Rules of Court, Rule 32, sec. 13a)