In January 2019, the BIR sent (by registered mail) a Final Assessment Notice to Baskin Robbins Co. for deficiency tax liabilities for the taxable year 2015. The FAN was sent to Baskin Robbins Co's former Taguig City address. The BIR also sent a "Notice Before Issuance of Warrant of Distraint and Levy" to the residence of one of BRC's directors. In March 2019, BRC protested the FAN on the grounds of lack of due process and prescription. As the CIR failed to act on the protest, BRC filed a Petition for Review with the CTA. Was there a valid issuance of the FAN by the CIR? Why or why not? *