Practice question
A taxpayer alleges collection methods are patently unlawful and asks to reduce or dispense with security pending CTA review. The parties’ factual assertions are disputed, and no preliminary evidence has been received. Under Pacquiao MAIN, what is appropriate before deciding that factual request?
- A CTA preliminary hearing and evidentiary determination of the asserted illegality and jeopardy
- Automatic waiver based solely on the taxpayer’s allegation
- Automatic rejection because the lifeblood doctrine forbids every inquiry
- A Supreme Court factual finding without any evidentiary basis
- Cancellation of all tax laws until the dispute ends
Legal references
- Spouses Pacquiao v. CTA, GR213394, April6 2016 MAIN: https://lawphil.net/judjuris/juri2016/apr2016/gr_213394_2016.html MAIN remand for preliminary hearing on reduction or dispensation of security.
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