Practice question
A criminal tax violation involves fraud but has not yet been filed in court. The taxpayer says it is compromisable under Section 204 solely because no court case exists. Which is correct?
- No filing means every violation is compromisable
- Fraud matters only after conviction
- The taxpayer may end criminal liability by unilateral tender
- Fraud is an independent statutory exclusion; absence of a court filing does not remove it
- All civil tax liability disappears too
Legal references
- NIRC, Section 204(A)-(B): https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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