Practice question
A taxpayer timely sends a letter unequivocally objecting to an assessment and stating its legal reasons. The treasurer merely acknowledges it and asks for a formal protest. Months later, the taxpayer repeats the same objection and claims the repetition first starts the treasurer’s decision period. Assume the original letter was sufficient and no exception applies. Which is correct?
- The first effective protest supplies the reckoning point; repeating it does not restart the period
- Every reminder restarts all statutory periods
- The treasurer can nullify an effective protest by requesting another caption
- Only the taxpayer’s preferred date matters
- Acknowledgment automatically grants the protest
Legal references
- China Banking v City Treasurer GR204117 July1,2015 MAIN: https://lawphil.net/judjuris/juri2015/jul2015/gr_204117_2015.html MAIN reckoning from January15 rather than March27 letter.
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