Philippine Bar review · Question

Practice question: Burden of Proof in Tax Assessments

Multiple Choice Easy

Practice question

Does Section 6(C)’s estimation power make every surveillance extrapolation conclusive under Elric Auxiliary (2026)?
  1. Yes, no rebuttal is possible
  2. Only if the calculation uses a spreadsheet
  3. Yes, any number is enough
  4. Only if the business is small
  5. No; the estimate remains subject to reasonableness and must not be arbitrary

Legal references

  • CIR v. Elric Auxiliary Services Corporation, G.R. No. 226945, February 19, 2026, main decision: https://lawphil.net/judjuris/juri2026/feb2026/gr_226945_2026.html

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