Practice question
A taxpayer seeks direct judicial resolution of a local-tax dispute stipulated to involve only interpretation of controlling statutes, no factual controversy, and the same pure legal issue addressed by NPC v Sual. It invokes the recognized exception to administrative exhaustion. Which is most accurate?
- The MAIN decision recognizes a pure-question-of-law exception; exhaustion is not absolute
- Every allegation of illegality eliminates all procedural requirements
- Direct court action is never permitted in any local-tax dispute
- The exception automatically resolves the substantive tax merits
- A disputed accounting computation necessarily becomes a pure legal question
Legal references
- NPC v Municipality of Sual GR226716 July10,2023 MAIN: https://lawphil.net/judjuris/juri2023/jul2023/gr_226716_2023.html MAIN exhaustion discussion; facts are expressly stipulated to fit the pure legal exception.
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