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Philippine Bar review · Question

Practice question: Burden of Proof in Tax Assessments

Multiple Choice Medium

Practice question

The BIR annualizes sales from a short operating period, but reliable undisputed records show the business was closed for most of the year. It refuses to consider the closure. Which is correct?
  1. The extrapolation is irrebuttable
  2. The closure evidence must be assessed because the annualization still must be reasonable
  3. Closure records are always irrelevant
  4. A short sample proves continuous operations conclusively
  5. The taxpayer must manufacture sales during closure

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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