Practice question
A company denies receiving the final assessment. The BIR produces an authenticated postal return card signed by the company’s authorized representative and evidence linking it to the disputed notice. The company argues that only its president personally could receive it. Which is most accurate?
- Competent evidence of receipt by an authorized representative can establish service; personal receipt by the president is not invariably required
- Only the president’s personal signature can ever prove delivery
- All postal evidence is legally irrelevant
- Denial alone conclusively defeats every authenticated service record
- Authorization never matters
Legal references
- CIR v Fitness By Design GR215957 November9,2016 MAIN: https://lawphil.net/judjuris/juri2016/nov2016/gr_215957_2016.html MAIN definite tax demand and payment due date.
- CIR v Villanueva GR249540 February28,2024 MAIN: https://lawphil.net/judjuris/juri2024/feb2024/gr_249540_2024.html MAIN proof of receipt of assessment notices.
- NIRC RA8424, Sections203,222–223 and228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section228.
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